EXECUTIVE SUMMARY Proponent Indorama Eleme Fertilizer and Chemicals Limited (IEFCL) is a company organized and existing under the laws of , with its registered office at Indorama Petrochemicals Complex, Eleme, , , Nigeria. IEFCL manufactures 2300 MTPD Ammonia & 4000 MTPD Urea Fertilizer (IEFCL-Train 1) at its Eleme manufacturing complex. IEFCL is undertaking the development of IEFCL-Train2 fertilizer project to increase the production of Urea adjacent to the IEFCL-Train 1 within the existing manufacturing Indorama complex at Eleme.

Need for the EIA This project has been categorized as category one project by the Federal Ministry of Environment (FMENV), who confirmed the need to conduct a full blown EIA.

Terms of reference (TOR) The Terms of Reference for this Environmental Impact Assessment (EIA) study include the following:  Determination of the baseline environmental profile in and around the proposed project site.  Rendering a qualitative and quantitative description of the physical, chemical, biological and social environments relevant to the project.  Documentation of significant signposts, including the identification of potential impact and risks of the project on the surrounding environment at large.  Recommendations and implementation of strategies to eliminate or reduce identified adverse impacts and risks  Production of an Environmental Impact Assessment (EIA) report with effective Environmental and Social Management Plan (ESMP)

EIA Objectives The objectives of the EIA are:  Assessment of the state of the environment  Establishment of environmental issues and factors associated with the proposed fertilizer project.  Assessment and forecast of all possible and potential impacts of the proposed project on components of the environment in terms of magnitude and importance.  Evaluation of project alternatives and identification of the option having least potential environmental impact.  To describe the physical, chemical, biological and socio-economic features of the environment potentially affected by the Project and identifying the environmentally sensitive areas within the project area.  Identifying the environmental impacts (both positive and negative) which may occur in the design, construction, commissioning, operation and decommissioning phases of the project.  To superimpose all aspects of the project on the environment and evaluate the overall impacts of the project on the environment.  To recommend any measures that could be used to avoid, and if not avoidable, mitigate/ameliorate any negative hazardous impacts as well as promote beneficial effects of the project.  To use results of the investigations to develop project specific ameliorating plans/measures during execution.  To define an Action Plan, which foresees the adoption of an Environmental and Social Management System (ESMS) for the project lifespan as defined by the Equator Principle no.4  To serve as an advance notification to the regulatory agencies especially the Federal Ministry of Environment.  To provide necessary answers to questions from stakeholders, host communities, regulators and other interested parties.

Scope of work of the EIA The scope of the EIA included review of laws, regulations and guidelines (National and International), fieldwork, laboratory analysis, literature research to assess the impacts expected and mitigation/compensation measures against negative impacts. In order to achieve this, informal and formal consultations were held with all interested parties. Based on the body of work described above, the EIA Report including comprehensive project/social and environment components description and an Environmental and Social Management Plan has been prepared and submitted to FMENV, the esteemed federal regulatory authority to process the report.

Regulatory Framework The Legal basis for environmental permitting, applicable National and International Legislative and Administrative framework including international laws and conventions pertaining to this industry were reviewed and documented. The EIA Report was drafted taking into account the following national and international documents also:  Guidance on EIA, EIS review, June 2001, European Commission;  Equator Principles, June 2013, Equator Principles Association;  International Finance Corporation (IFC) Sustainability Framework, 2012 Edition, Performance Standards;  Environmental, Health and Safety Guidelines, April 30 2007, World Bank and IFC;  Environmental, Health and Safety Guidelines for Nitrogenous Fertilizer production, April 30 2007, World Bank and IFC;  EIA Procedural Guidelines, 1995, Federal Environmental Protection Agency of Nigeria;  EIA Sectoral Guidelines, Oil and Gas Industry Projects, Sub-sectoral Guidelines for Petrochemicals, 1995, Federal Environmental Protection Agency of Nigeria;  EIA Sectoral Guideline, Manufacturing Industry  Environmental Impact Assessment Act 86 of 1992  Rivers State Environmental Protection Agencies Edict No 2 1994  Rivers State Noise Control Edict, 1985  Rivers State Waste Management Agency Law No.2, 2014  Pollution Compensation Tax Edict, 1994 Justification of the project The gross imbalance in the supply and demand of fertilizer for agricultural productivity in Nigeria goes to support the need to establish fertilizer plants. The use of Natural gas for production of fertilizer will support Federal Government’s Gas Revolution Policy on alternative uses for natural gas instead of the wasteful practice of flaring.

The project will help achieve the objectives of the federal gas revolution programme providing necessary infrastructure for natural gas based industries, thereby boosting the Nigerian agricultural sector by providing the most crucial agricultural input. The current economic diversification and agricultural policies of Nigeria promotes the responsible use of green revolution technologies namely fertilizer, in the efforts to achieve food security and for generating exportable surplus of farm products in a market-friendly way.

Urea is the most important nitrogen based fertilizer worldwide and is not considered hazardous or toxic.

The project will also contribute to increase the competitiveness of local and regional agriculture by enabling the sale of fertilizers at competitive prices.

Project Alternative In determining the project options, issues such as ease of availability of raw materials, choice of appropriate location and best available technology for producing the products were reviewed. These formed the basis of suggesting that the chosen project option is the more appropriate solution for the development of the project.

Project Location The project is located geographically within 4o49’N and Longitude 7o6’E. Maps of Nigeria, Rivers State and study area around Indorama complex, together with the plot plan of Indorama complex, were used to illustrate the proposed location of Ammonia and Urea Plants in Eleme (the Host community).

Project Description To simplify the understanding of how the final product Granular Urea will be produced from the parent raw material, which is natural gas, block diagrams starting from the desulphurization of the natural gas, catalytic steam reformation of the gas into hydrogen, carbon dioxide and carbon-monoxide, catalytically shift conversion of carbon monoxide to carbon dioxide, selective adsorption of carbon dioxide and synthesis of ammonia from balance gas containing hydrogen and nitrogen were used. Ammonia and Carbon dioxide sets the stage for chemical reactions in Urea plant to end up with Granular Urea product.

The project entails the building of the following two process plants: - Ammonia Plant for the production of 2300 MTPD of Ammonia; - Urea Plant for the production of 4000 MTPD of Urea.

The project design shall be suitable for 30 years of operation with planned turn around maintenance every 3 years or longer. Design capacity is considered for an on stream days of 330 days/year. IEFCL has engaged Technology licensors /EPC Contractors for undertaking front end engineering design (FEED) & getting firm bids employing state of the art technology, optimum energy consumption & most environment friendly process.

For the purpose of the Environmental Impact Assessment, conservative approach has been adopted and highest levels of emission and discharge have been taken into account for pollutant dispersal monitoring. However the emissions of the new plants will be in compliance with the applicable International standards/requirements, in particular concerning the Nitrogenous Fertilizer production. The proposed project shall be supplied with the utilities ((e.g. electric energy, waste water treatment etc.) from within the Indorama manufacturing complex where adequate utilities generation equipment shall be added.

Environmental and Social Baseline Ecology The objectives of the study was to examine the potential impacts that might be associated with the establishment of the IEFCL-Train2 fertilizer plant on the ecology of the area with emphasis on the vegetation (flora) and wildlife (fauna) in the area. In view of the aforementioned, the study area is classified under the Eleme industrial belt. However, in the study of ecology which covered thematic region of 5km radius, a total of 13 tree/shrub species within 12 families with Elaeisguinensis being the only common species and Apocynaceae being an occasional family was observed in the area. Similarly, a total of 18 herbaceous species occurred in the area within nine families. On the other hand, a total of 21 faunal species were observed to be found in the area and they comprised of mammals, rodents, wild ruminants, reptiles and aves. Invariably, the plant health conditions were also analyzed and it was ascertained that the vegetation in the area was in good condition in spite of a few diseases symptoms that were associated in the area. Environmental management plan proffered for the project will ensure yearly monitoring of the ecology of the influenced area of the project

HYDROBIOLOGY Phytoplankton The phytoplankton communities were represented by four taxonomic groups in the dry and wet seasons. The groups are: Bacillariophyceae (diatoms), Chlorophyceae (green algae), Cyanophyceae (blue green algae) and Euglenophyceae. Forty-eight (48) species were identified with the Bacillariophyceae dominating the phytoplankton community in the wet season and Cyanophyceae in the dry season. The seasonal changes in the species composition and population density maybe attributed to the changing environmental conditions. Results of the ecological indices (Shannon-Weiner index) suggest effect of anthropogenic activity (sand mining) in both climatic regimes. The analytical results of the surface water lends credence to this finding. The order of dominance was as follows: Bacillariophyceae >> Chlorophyceae >> Cyanophyceae >> Euglenophyceae (Wet season); Cyanophyceae >> Bacillariophyceae >> Chlorophyceae (Dry season).

Zooplankton The zooplankton community comprised of Copepoda, Rotifera, Tintinidae, Cladocera and Cichlidae in the wet and dry season. A total of 4 species were identified in the dry season and 15 species in the wet season. The Rotifers were the most dominant zooplankton taxonomic group representing about 72.14% and 42.86% in the dry and wet season. The dominance of Rotifers maybe attributed to the presence of sediments in suspension in the surface water bodies. This suggest that the surface water body is stressed between both seasons, as result of the intense sand mining. In increasing order, the dominance pattern of the zooplankton community were Rotifera >> Copepoda >> Tintinidae (Dry season); Rotifera >> Copepoda >> Cladocera >> Cichlidae (Wet season).

Benthic invertebrates The Benthic invertebrates were represented by three taxonomic groups in the wet and dry season. The taxonomic groups are Oligochaeta, Insecta and Nauplii comprising of 4 taxa in the dry season and 10 taxa in the wet season. The insect dominated the benthic fauna community with a percentage composition of 75% in the dry season and 52.38% in the wet season. The dominance of Insecta is not uncommon in freshwater ecosystems as it has been reported to tolerate extreme conditions and high competitive capacity. The Shannon-Weiner diversity index suggests disturbed sediments in both climatic regimes. In increasing order, the dominance pattern of the benthic fauna were Insecta >> Oligochaeta (Dry season); Insecta >> Oligochaeta >> Nauplii (Wet season).

Ambient air The Ambient Air Quality, Noise and Meteorology study was conducted in the month of September in the wet season, while secondary data for previous studies conducted in the area were used for dry season analysis. The exercise was carried out in compliance with statutory requirements and in line with national and international policy on the protection and conservation of the environment. Monitoring locations within and outside the project area were chosen for the air quality study, an hourly mean monitoring was carried out for 8 hours as recommended by Federal Ministry of Environment (FMENV) and the United States Environment Protection Agency (USEPA). Baseline results were compared with FMENV and the National Ambient Air Quality Standards (NAAQS). The air quality study exercise was conducted using air monitoring equipment, while noise levels were measured using portable noise instrument. The parameters measured during ambient air study are: CO, SO2, NO2, H2S, THC, VOC, NH3 and particulate matter

(TSP, PM10 and PM2.5); meteorological parameters monitored are, temperature, relative humidity, wind speed, and wind direction. A total of nine (9) sampling locations were selected for the assessment of the existing ambient air quality status of the project area. Measurement of baseline concentration levels of particulate matter (TSP, PM10 and PM2.5), sulphur dioxide, nitrogen dioxide, carbon monoxide, hydrogen sulphide, ammonia, total hydrocarbons and VOCs was established. It was observed that average values of particulate matter (TSP, PM10 and

PM2.5) for all monitoring locations were well within FMENV, IFC and NAAQS limits. The average concentrations of SO2 and NO2 were well below statuary limits in both seasons.

The mean concentrations of CO, H2S, NH3, VOCs and THC were low (below both FMENV permissible limits) for all monitoring locations in the project zone.

Baseline concentrations of SO2, NO2 and H2S were generally low in both seasons. Mean 3 3 concentrations of NH3 was 0.12±0.13µg/m in wet season and 0.10±0.10µg/m in dry season. The average concentration of total suspended particulate matter (TSP) was 26.7±16.79 µg/m3 in wet season and 40.3±16.00µg/m3in the dry season. The mean 3 concentration of particulate matter PM10 was 17.9±10.81µg/m in the wet season and 25.6±11.75µg/m3 in the dry season; while the average concentration of particulate 3 3 matter PM2.5 was 8.8±6.09µg/m in the wet season and 14.8±5.14µg/m in the dry season. Baseline measurement showed that concentrations of air pollutants in the area are generally low. These values are well below the FMENV guidelines and represent baseline condition of the study area.

The environmental baseline describing the pre-construction air quality of the project area has been conducted through intensive measurements of air pollutants in the project area. Existing air quality in the study area is controlled by local weather condition and particularly the strength of the North-East and South-West trade winds that are prevalent in the area during the dry and wet seasons respectively.

Noise The average noise level in the wet season was 55.5±7.98 dB(A), while the average noise level measured within the project area was 63.2±7.01 dB(A) in the dry season. The measured noise level values are well below the FMENV guidelines and represent baseline noise level of the study area. Waste management Indorama utilizes the 4R (Reduce, Reuse and Recycle and Recover) as a basic principle of its waste management policy. The proposed Ammonia and Urea Plant IEFCL-Train 2 will use the existing incinerators at site for incineration of inenarrable wastes. New waste segregation units will be built for IEFCL-Train2 plants where solid waste will be segregated into properly labeled receptacles according to the types of waste from where it will be collected for final disposal. There is a dedicated scrap yard where large volume of waste is temporarily kept before reuse, recycling or disposal. Waste manifest, waste tracking, waste vendor certificate verification and vendor reassessment, waste quality assessment before final disposal are the quality control measures that will be used to assess the efficiency of the waste management scheme for the proposed project.

Effluent treatment Effluent streams comprising sewage, process waste water, and blow down are collected into dedicated pits and pumped via pipelines to respective treatment units where it undergoes processes such as hydrolysis, stripping, neutralization, demineralization, and equalization. The quality assessment of treated effluent is assured at ISBL treated effluent pit and at Effluent treatment plant (ETP) before final disposal.

Stack emissions Gaseous emission will be minimized by the plant process design including scrubbing and final emissions will be discharged via stacks. Most of the gaseous emissions from the plant will be normal atmospheric components - nitrogen, oxygen, carbon dioxide, water vapour and inert gases - that will be discharged via stack at an appropriate height.

Soil Soil Sampling Composite soil samples were collected at two depths: 0-15cm (Topsoil) and 15 – 30cm (Subsoil) with the aid of Dutch stainless steel hand auger from Seven (7) sites at different locations within the proposed project area and two control sites outside the project area. A total number of Eighteen (18) soil samples were collected.

Morphological properties The soils of the study area are coarse grained, gravelly, locally fine-grained, poorly sorted, subangular to well rounded (Assez,1975). Ojanuga et al (1981) stated that the genesis of these soils have resulted from cycles of soil formation which alternated with cycles of erosion in the mid tertiary to Holocene era in Nigeria. Soil consistency as observed during the field exercise were between wet (slightly sticky and non sticky) and moist (friable), while soil colour were between black (10YR2/1), Dark red (2.5/YR3/6), Brown (10YR5/3) and Strong brown (7.5YR4/6). The topography of the study area were relatively flat with some gentle slope as observsed around station one (SS1- Okulu Aleto). Physiochemical properties The textural classification of the two soil depths within the study area and control site was predominantly fine-grained fairly consolidated Loamy Sand, Sandy Loam and Sandy Clay Loam soil (using the soil particle size matrix), with considerably low clay content. The soil reaction falls within acidic pH range of 4.70–5.6 (5.22 ± 0.39) for topsoil and 4.30 -6.80 (5.37 ± 1.03) for subsoil indicating that the soil is slightly acidic, which is typical of a soil. The Organic matter content of the soil ranged from 0.09-0.21 at the topsoil, while the subsoil ranged from 0.08 – 0.16% indicating low organic matter content of both topsoil and subsoil according to FAO (1990) classification, which also reflected in the Total Organic Carbon results recorded during this studied Total Nitrogen levels ranged between 0.08 -0.39% and 0.08 – 0.27%for both the top and sub soil respectively indicating that Medium to high soil fertility according to FAO (1990) classification of soil Microbiology The total population of total heterotrophic bacteria (THB) ranged from 0.52x104 to 4.50x104(cfu/g) for topsoil and 1.50x104 to 3.95x104(cfu/g) for subsoil; total heterotrophic fungi (THF) ranged from 0.15x104– 1.59x104(cfu/g) for topsoil and 0.45x104– 2.00x104(cfu/g) for subsoil. The population of total hydrocarbon utilizing bacteria (THUB) ranged from 0.25x104– 1.96x104(cfu/g) for topsoil and 0.37x104– 1.99x104(cfu/g) for subsoil, and the total hydrocarbon utilizing fungi (THUF) ranged from 0.64x104– 3.00x104(cfu/g) for topsoil and 0.22x104– 3.50x104(cfu/g) for subsoil,

Heavy metal Heavy metals analysis in the soil samples revealed Iron (Fe) having the highest concentration (Mean 6847.25mg/kg topsoil and 6685.20mg/kg subsoil), while mercury (Hg) and Vanadium (v) were below detection limit. Conclusively, soils of the area with the exception of some localized variations are characterized by the following very good physical features, poor inherent fertility status, low degree of acidity Low cation exchange capacity FAO (1990) and Predominant sandy texture

Surface Water The water body is a fresh water body with pH slightly acidic at the upstream which is typical of the Niger delta surface water bodies. The pH during the rainy season fieldwork (2017) ranged from 6.80 to 6.95 and 6.55 – 6.60 at the control stations compared to 6.0 to 6.67 and 7.40 for control station for dry rainy season sampling (2011). All parameters analyzed during study show compliance to existing regulatory standard.

Sediment The color of the sediment samples ranged from black to dark grey coloration. The silt fraction was higher than the sand and clay content making the sediment Silty in texture. Nutrients are adequate to support the healthy growth of benthic population. The concentrations of nutrients in sediment around the study area are indicated below; Sulphate concentrations varied from 51.8 to 483.5 mg/kg and 185.7 to 362.7 mg/kg for rainy season (September 2017), nitrate content ranged from 2.64 to 19.23 mg/kg and 8.22 to 10.4 mg/kg control stations for rainy season. Total Petroleum Hydrocarbon was low for all samples taken 9.62 to 18.22 mg/kg and control stations with 2.90 to 4.76 mg/kg for rainy season.

Socio Economic and Cultural Environment The IEFCL-Train2 project will generate a lot of interest and expectations from the host communities. For investigating the socio economic component a dedicated questionnaire and focused group of interviews were the primary means of data collection. Four communities in two local government areas of Rivers State of Nigeria where surveyed for this study. The communities are Agbonchia, Aleto and Akpajo in Eleme Local Government Area and Elelenwo in Obio/Akpor. The people of Eleme claim a common ancestry, language and ethnicity. Elelenwo is of Ikwerre origin. Among Aleto and Agbonchia settlements, there are also three family units, respectively Okerewa, Njuru and Akpankpan. Okerewa is studied under Aleto, while Njuru and Akpakpan are covered under Agbonchia.

The total population of the four communities surveyed in this study is 65,956 in 2010 (field survey). The population structure based on a pyramid plot is heavy at the bottom and light at the top. Children (0-14) in the communities constitute 36 percent of the population. The working class (15-60) constitute 59 percent, while old and retired people (> 60) constitute 5 percent of the population. The largest age cohort is infants aged between 0-4 years and they constitute 16 percent of the population. There are more male (57%) than female (43%) among the households surveyed in this study. The mean household size is 5, the same as the national average. This gives a sex ratio of 106 compared to the national sex ratio of 105. The distribution of occupation among the respondents is 48 percent for the self-employed, 21 percent for those who work in government offices, 12 percent for company workers and 22 percent unemployed. Only 2 percent of the respondents claim they fish. The mean daily income of people in the study area is N400 or 2.6 USD per head per day.

Large industrial complexes prior to the entry of Indorama in the region have not attracted medium manufacturing industries to utilize their products in the area. This lack of backward integration permeates to the level of small aspiring entrepreneur. As reflected in the occupation structure, people either farm, work for government or do small business. Outside the large industries in Eleme local government area, the other common enterprises are contractors, vendors, welding/ fabrication workshops, sand mining, and traditional food processers. The farming system is a limited form of shifting cultivation whereby a land is cleared and cultivated for several years until productivity diminishes; it is then abandoned until natural processes regenerate the soil. The fallow period was up to 7 years about 30 years ago, it reduced to about 4 years 10 years ago, but now the farms are rarely left fallow. Farming tools and inputs are also basic. Seedlings are obtained from the previous year’s harvest. Cutlasses, hoes and spade make up the farming tools. Mechanization is non-existent.

The sole source of domestic water supply is shallow boreholes. The water tables in the study areas are close to the surface and water can be tapped at 10m in most cases from the first aquifer.

Movement from one place to another is by road in the communities studied and major means of transportation is motor, bicycles, 2-stroke tri-cycles (popularly called Keke- NAPEP and buses). All the study communities are big enough to require some sort of internal transport which is met through the use of tricycles. In Aleto and Agbonchia motor bikes are the most important means of internal transport. Every community in the study area has a model primary school. All the communities also have a secondary school. Adult literacy rate in the study communities is commendable.

Energy demand in the study area is for lighting, cooking, and driving machines (including automobile). The experience during the fieldwork is that all energy types are in short supply. Electric power is erratic and there are occasions when they receive only a few hours of power in a week. The petroleum based fuel are scarce and expensive, like kerosene and cooking gas for domestic use, which gives credence to the dependents of wood as a major source of domestic fuel.

Most respondents live in own houses. Majority of the houses are constructed with concrete blocks and roofed with corrugated iron sheets. Other types of houses reported by respondents are concrete blocks roofed with iron sheets, earth block and iron sheets, and the traditional wattle and mud houses roofed with thatch or iron sheets. The average households is between eight/nine persons. Four activities dominate the cultural calendar of communities in the study area namely; wrestling, traditional marriages, new yam festival and dances. The only surviving historical forest as a result of rapid industrialization in the area is the Onura forest. Social Affiliation in the societies includes politics, co-operatives, social clubs, education, religion and cultural associations. Dispute over land boundary and ownership is the primary cause of intra and inter communal conflicts in the study settlements. The courts are the main avenue for dispute resolution.

Traffic Survey The four communities in the study area are traversed by two major highways: the East – West Road that begins from Warri and end in and the Port Harcourt – Aba Expressway. A survey of the existing traffic volume on the East- West Road (Direction from Akpajo to Port Harcourt) indicated that Indorama complex will affect traffic volume during the peak hours of 8:00am to 9:00am and 5:00pm to 6:00 pm. In view of the findings, traffic management plan has been instituted by Indorama.

Health Assessment The Health Assessment of the project area was conducted in and around the facilities and the communities to determine the baseline characteristics of the health status of the project area against which future impacts of the project can be compared. Secondly to determine the probable/potential impacts of the project on the health of the workers within the IEFCL facility, the people around the communities (Agbonchia, Aleto, Akpajo, and Elelenwo) so as to determine the type of intervention/s needed to ameliorate these negative potential impacts. These communities were sampled by the health personnel to obtain information regarding mortality and morbidity rates, types of health hazards, most prevalent diseases, disease vectors, nutrition, health facility infrastructure capability and usage, average family size, sexual reproductive health, immunization status and coverage, sewage and waste management system, air quality, water quality, radiation sources and levels. The state of health delivery facilities/services in the area is below standards expected of an urban area. The principal communicable diseases in the area are Malaria, Diarrhea, skin rashes, upper respiratory tract infections and STIs. While prevalent non-communicable diseases in the area are hypertension, food poisoning and occupational injury.

Associated and Potential Impacts Associated and potential impacts evaluation for the project was based on the results of technical studies, together with established facts in relevant literatures, perceptions and evaluations of stakeholders, project characteristics and general observations obtained during field data gathering.

For all project phases (Construction, including recruitment phase and site preparation, Operation & Maintenance and Decommissioning) activities that can affect the environmental and social components have been identified, together with potential and associated impacts. Also the Health & Safety issues have been similarly considered.

Occasionally hydrocarbon odor is perceived in the study area; traffic volume variations & associated issues are experienced. Positive impacts include capacity development, job opportunities and vendor patronage for host communities and increase economic activities in the study area in particular.

Cumulative Impacts The proposed project will be sited in the existing Indorama complex, where already IEFCL-Train1 operate in addition to other plants. Therefore the cumulative impact assessment was conducted to ascertain the combined effect of the operating unit & proposed project to the valued environmental component (VECs) immediate to this facility in order to proffer mitigation measure. Based on the individual impact assessment for the projects, majority of the cumulative impacts would occur during the operational phase only, as construction is not expected to coincide with any other construction within the Indorama complex. Most of the cumulative effects would occur, when there is an overlap of activities. These activities will be taking place within an area of about 2 km2 radius.

The cumulative positive impacts identified are  Business Opportunity/Economic enhancement  Skills acquisition  Increase in revenue for the Government, Community and Indorama The cumulative negative impacts identified are:  Increase in cost of living/Inflation during construction  Increase in potential for road traffic volume  Stress on existing security structures during construction The significance rating of each of these impacts has been obtained through the process of impact identification, ranking and quantification, in each of the project phases.

The evaluation of impacts in the different phases of the initiative considered the predicted implementation of the above mentioned actions and it is briefly reported hereinafter.

Mitigative Measures Various mitigation measure, (technical and administrative) are proffered specific to environmental problems that may arise during construction, operations and even abandonment and decommissioning stage. An environmental and social management system will be adopted to help enhance the results of the mitigation measures.

Construction Phase During construction phase IEFCL will put in place all the necessary measures to ensure health of workers and environmental safeguard and to minimize the risk of possible incidental events. The slight increase in dust emissions from construction activities will be properly addressed by spraying water at construction sites to reduce powder dispersion, when construction is carried out in dry season. The construction activities will be carried out, also, in accordance with applicable regulations on noise. Increment in vehicular movements will occur during construction phase, however, the Project will have minor effects on the existing vehicular transit on main road axes around Indorama complex, because of adherence to IEFCL’s Traffic Management Plan. Temporary and occasional impacts on vibrations are expected, but considering the distance of sensible receptors between the Indorama complex and the host communities, occasional vibration will have no impact on the receptor. Risk of ground water/soil contamination due to accidental spills during construction activities is a minor concern that will be minimized through the adoption of dedicated management measures into the ESMS. The construction activities will take into account the soil geological and geotechnical characteristics avoiding the execution of the main foundations during the wet season in order to exclude possible soil erosion concerns. Construction areas are located inside the industrial complex under the control of Indorama, without using virgin land. During this phase, IEFCL will make adequate accommodation arrangements for expatriates to reduce pressure on local houses. Minor impacts on wildlife are expected and time limited, associated to diurnal hours. Current fruition of the existing fauna will not change. Waste production during construction phase will be managed by the procedures and facilities already existing in the Indorama complex. The excavated soil not reusable for geotechnical reasons will be directed to appropriate external authorized landfills. A population increase in the near host communities associated to the realization of the Project is expected. Dedicated policies and actions will be adopted by IEFCL to safeguard the host communities from impacts due to the influx of workers, however the host communities will particularly benefit of the increase of both direct and indirect employment.

Operation Phase During the operation phase, IEFCL will put in place all the necessary measures to ensure health of workers and environmental safeguards to minimize the risk of possible incidental events. No significant effects are expected on air quality during operation phase, since the pollutants concentrations at ground level at the INDORAMA complex after the operation of the new Fertilizer plants will be in compliance with air quality regulatory/standards guidelines and within the limits of occupational exposure. No cases of odor annoyance are expected due to NH3 emission since facility to burn off Ammonia has been incorporated. The project will not add to air emissions that will negatively affect the existing quality of vegetation around the complex. Moreover, fugitive emissions and emissions can occur in upset situations only (e.g. emissions from ammonia storage flare) and in case of such emissions adequate flaring facilities have been provided. Such incidents shall be well managed by a dedicated Management Systems. Night-time vehicular movements will be minimized up to extent possible. IEFCL will ensure that the operation of the new plants will be in accordance with applicable regulations on noise. Water effluents going to existing retention pond and to Okulu Stream will increase due to the operation of the new Fertilizer Plant. This is not likely to generate an additional deterioration of surface water and its hydrobiology/sediment because ccompliance with regulatory limits at discharge point will be ensured after the operation of the new Fertilizer Plant. As a consequence, no variation in existing surface water quality likely to modify the characteristics of surrounding vegetation is expected. The water consumption by new project will not affect the water table. The ground water recharge rate and the existing ground water flows will remain same. The risk of ground water/soil contamination due to accidental spills during operation will be minimized through the adoption of dedicated management measures. The project may have negative Health Impact on the host communities around IEFCL complex due to the influx of workers who are possible carriers of some communicable diseases. The same population increment in the near host communities will be managed in a proper manner to safeguard the health of host communities through the various health intervention programs organized by IEFCL HSE and Health Department. IEFCL will construct new residential facilities inside the complex for expat staff only. Also an acceptable increase of vehicular traffic is expected and will be adequately managed in order to minimize possible socio economic impacts and potential associated hazards. There are no socio-economic activities that are going to be negatively affected by the project and the installation of new units will not interfere with cultural/social elements present in the study area. The initiative will not modify the existing microclimatic conditions of the site considering also the expected increment of aqueous vapor emissions in atmosphere from Cooling Towers. The catalytic steam reformation of Natural gas (major raw material) produces CO2 among other gases which used for synthesis of NH3. The technology of using CO2 and

NH3 to produce Urea prevents CO2, a greenhouse gas, been emitted into the atmosphere. Optimal use of Natural gas for the production of fertilizer in this project will reduce the release of associated greenhouse gases, being emitted in to the atmosphere due to gas flaring from the oil production fields.

Environmental Management Plan (MP) IEFCL has defined a plan for managing the proposed project and associated impacts related to environmental and social impact and occupational health and safety concerns. The MP includes strategies to enable proactive resolutions of the environmental and social impacts expected, procedures for training, development of adequate capacity; plans for monitoring environmental, social, occupational and health issues as well as management of the effects of the impacts and minimization of the risks, parameters to be measured/monitored, frequency and location of monitoring. The plan is aimed at adopting an Environmental and Social Management System in accordance with the IFC Performance Standard no° 1.

The ESMS adopted at IEFCL is based on the best practices adopted in the same kind of industries globally. The systems and procedures practiced at IEFCL are in line with globally accepted international standards, like ISO 14001, OHSAS 18001 etc. The IEFCL- Train2 project is an expansion of IEFCL-Train1 and the same systems and procedures will be extended to new plants.

Decommissioning Phase At the end of the life span of the project, or otherwise, if proponent and or government decides to decommission the project, a plan would be drawn by the proponent and approved by all concerned Regulators and stakeholders before the plan is executed. All possible measure will be taken in order to ensure health of workers and environmental safeguard and to minimize the risk of possible incidental events during decommissioning phase. IEFCL commits itself to restore the environmental conditions existing before the realization of the IEFCL-Train2 Fertilizer Plant project. Conclusion Evaluation of EIA data, found that the project is environmentally feasible and will not cause serious effect to the environment, considering that the existing and proposed mitigation measures are implemented. Residual issues associated with the project are expected to be minor and not likely to have long-term significance on the environment.

Recommendation Mitigation and compensation measures are to be addressed according to the proposed action plan. All its monitoring programs are to be religiously implemented and periodically reviewed and revised as necessary to take into consideration changes made to the project during its operation. Vibrant and dynamic company-community relations need to be maintained to ensure sustainability of the project.

ACKNOWLEDGEMENT

The management of Indorama Eleme Fertilizer and Chemical Ltd (IEFCL) wishes to acknowledge the opportunity granted by the Government of Federal Republic of Nigeria through the Ministry of Environment to conduct this EIA for the proposed IEFCL-Train2 fertilizer plant in the Indorama complex, Eleme.

We appreciate the cordial working relationships we had with the Federal Ministry of Environment, the Rivers State Ministry of Environment, during consultation and fieldwork. The Eleme Local Government Council and the Traditional Head of Eleme Kingdom, during the field data gathering exercise and the stakeholder’s engagements.

Thank you,

Management of IEFCL

IEFCL -Train2 Fertilizer Project EIA Report

CHAPTER ONE BACKGROUND INFORMATION

1.0 INTRODUCTION Indorama Eleme Fertilizer & Chemicals limited is a major producer of Urea fertilizer situated on a site of approximately 26 hectares within the Indorama manufacturing complex at Eleme. The manufacturing facility is located about 15 kilometers North East of the Port Harcourt, the capital of Rivers State. Indorama Eleme Fertilizer & Chemicals Limited (IEFCL) is the proponent of the proposed expansion of Fertilizer plant.

1.1 THE PROPONENT The proposed expansion of Urea (Nitrogenous Fertilizer) Project is planned to be set up within the existing - Indorama manufacturing complex near by the existing Urea plant. The proposed expansion, termed IEFCL-Train2 will consist of Ammonia / Urea train with a total operating capacity of 2,300 metric tons per day (MTPD) of ammonia and 4,000 MTPD of urea. The associated off sites and utilities necessary to make the proposed plant self-supporting in terms of power, water, and other auxiliary systems are discussed under project description (Chapter 3).

The existing fertilizer manufacturing facility (The Train 1 facilities) also consist of 2300 MTPD of Ammonia & 4000 MTPD of Urea Plant, product warehouse, bulk loading and bagging, ammonia storage, associated utilities units such as are made up of DM plant, effluent treatment etc.

The units of the complex are illustrated in the attached plot plan (Appendix 1.1), which also clearly indicates the location of the proposed expansion of fertilizer plants.

The construction of the proposed plant termed IEFCL-Train2 is expected to commence its Engineering and Procurement by the end of year 2017 & Construction activities are expected to commence in 1st quarter of 2018.

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The company IEFCL, was incorporated on 23rd of August 2010 with registered office in Indorama complex, Eleme, Rivers State, Nigeria. . The construction of Train1 plants were started in April’ 2013 and were successfully commissioned in May’ 2016. Since then the plants under Train 1 are operating successfully.

The company would rely on a mixture of professional expatriate staff and Nigerian staff from the rich human resource of Nigerian. Total direct employment for the operation of the new IEFCL-Train2 will be 200 employees of which about fifty (50) will be expatriates. During construction peak period, manpower needs will be about 4000 personnel from and within Eleme & Port Harcourt, while during the decommissioning phase of the project manpower utilization is estimated at 120. (Most of them will be Nigerian).

For the development of the project, the company will respect the IFC Performance Standard 2 concerning the Labor and Working Conditions (refer to the Environmental and Social Management System, Chapter 7 for more details).

1.2 NIGERIA Nigeria is the largest and most populous country in sub-Saharan Africa. It lies between latitudes 4o and 14o North of the Equator and longitudes 3o and 14o East of the Greenwich Meridian. The current population of Nigeria is 192,222,138 as of Sunday, October 8, 2017, based on the latest United Nations estimates. Nigeria population is equivalent to 2.53% of the total world population, ranking number 7 in the list of countries (and dependencies) by population. The population density in Nigeria is 210 per Km2 (543 people per mi2), with a total land area of 910,770 Km2 (351,650 sq. miles), where 50.2 % of the population is urban (95,764,092 people in 2017) Worldometer 2017. It is bordered by Chad and Niger Republics to the North, Cameroon to the East; Republics of Benin and Togo to the West and the Atlantic Ocean to the South. It is made up of several ethnic groups, the major ones being Hausa, Fulani, Igbo, Yoruba, Edo, Efik Ijaw and Kanuri.

For identifying the location of the initiative (Nigerian State and Local Government) see:

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 Map of Nigeria showing Rivers State, among the thirty six states of Nigeria (Plate 1.1);  Administrative map of Rivers State showing the position of Eleme Local Government Area (Plate 1.2)

Plate 1.1: Map of Nigeria Showing Rivers State.

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Plate 1.2: Administrative Map of Rivers State showing the Host LGA (Eleme) of the Project Site.

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1.3 NEED FOR THE ENVIRONMENTAL IMAPCT ASSESSMENT Since 1992, the Federal and State Governments through various enactments and regulations require an Assessment for any development project (private and public) that is likely to impact significantly on the Environment. New projects were to undergo an environmental impact assessment (EIA Act 86, 1992) prior to construction and/or operations commences on site.

The building of the new Nitrogenous Fertilizer (Ammonia and Urea) plant, IEFCL-Train2, within the existing Indorama complex has been categorized as ‘category One’ project by the Federal Ministry of Environment and thus required to conduct a full blown EIA procedure (Appendix 1.2 - FMEnv TOR Approval). It is in this context that IEFCL has conducted this Environmental Impact Assessment of these proposed new plants.

Dedicated scenarios considering the cumulative effects of both the Fertilizer Plants and existing operating plants into the complex are included in the EIA report.

1.4 TERMS OF REFERENCE [TOR] OF THIS EIA The proponent carried out a scoping procedure to ensure that all significant impacts and reasonable alternatives would be addressed in the intended EIA. A systematic approach was adopted during scoping activity to verify that all the aspects have been considered. The proponent submitted a Terms of Reference (TOR) on 21st August’ 2017 indicating the scope of the proposed EIA study. Discussions were held with the proponents and the various heads of the contributing consulting units and the EA department Regulatory Agency (Federal Ministry of Environment Abuja). This resulted in the above of the TOR/Scope of the EIA studies and Categorization of the project by the Federal Ministry of environment Abuja vide their letter of 18th September 2017 (Appendix 1.2)

The TOR of the proposed EIA study included:  The plan of environmental investigations to be carried out to identify the baseline condition of the study area;

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 The format and contents of the EIA report;  The description of the team charged to prepare the present EIA report.

The Federal Ministry of Environment communicated to the Proponent on 18th September’2017 for approval of the TOR (Appendix 1.2).

1.5 EIA OBJECTIVES The present EIA study analyses the social and environmental impacts expected by the realization and operation of the Fertilizer plant, including also the possible associated health and safety risks.

In view of the above, the objectives of the EIA are:  To describe the physical, chemical, biological and socio-economic features of the environment potentially affected by the Project identifying the environmentally sensitive areas within the project area.  Identifying in the design, construction, commissioning, operation and decommissioning phases of the new Fertilizers plant where environmental impacts (both positive and negative) may occur.  To superimpose all aspects of the project on the environment and evaluate the impacts of the project on the environment.  To highlight particularly and recommend any measures that could be used to avoid, if not avoidable, mitigate/ameliorate any negative hazardous impacts as well as promote beneficial effects of the project.  To use results of the investigations to develop project specific ameliorating plans/measures during execution.  To define an Action Plan, which foresees also the adoption of an Environmental and Social Management System (ESMS) for the project lifespan as defined by the Equator Principle No.4.  To serve as an advance notification to the regulatory agencies especially the Federal Ministry of Environment.

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 To provide necessary answers to questions from stakeholders, host communities, regulators and other interested parties. 1.6 SCOPE OF WORK OF THE EIA The following activities have been carried out to achieve the EIA objectives, discussed in par. 1.4:  Review of State, National, and International environmental regulations, standards, codes and conventions relevant to the proposed project activities.  Review existing literature on the study area, including studies reports (EIA, EER, etc.) if any, in order to come out with a baseline profile.  Field sampling/testing at the project site.  Review methods used for field work and laboratory analysis.  Developing a questionnaire to collect pertinent in-house and community based information and Health Impact assessment.  Consultation with stakeholders and regulators. The evaluation, of their observation/ inputs/perceptions.  Description of the Project.  Analysis of the Health and Safety Risks.  Assessment of associated and potential impacts of the fertilizer plant.  Developing cost effective mitigation measures and monitoring plans.  Preparing draft and Final EIA report that meet regulatory requirements.

1.7 EIA METHODOLOGY The approach adopted for this study was multi-disciplinary covering the pure sciences and social sciences. Standard methods as approved by the Federal Ministry of Environment (FMENV Guidelines and Standards, 1991) and American Public Health Association (APHA standard methods) were adopted for sample collection and analysis. Field research, consultations, impact identification and evaluation (checklist, matrix, etc.) were other aspects of methods used in this study. The environmental surveys and sampling activities discussed in the present document were carried out under the supervision of FMENV (Appendix 1.3 - Letter of nomination of field work supervisor from FMENV). The spatial boundary of the study area covers five (5) Km radius from the

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1.8 REGULATORY FRAMEWORK 1.8.1 Legal basis for Environmental Permitting Environmental planning and permitting in Nigeria is carried out through the provisions of environmental legislation i.e., the Federal Environmental Protection Agency Act (FEPA) of 30th December, 1988. Besides, there are many laws aimed at protecting the environment and preserving natural resources, as highlighted below.

Part VII, Section 30-1, Miscellaneous provisions of NESREA Act 25, 2007 defines “Environment” as "including water, air, land, and all plants, animals, and human beings living therein and the inter-relationships which exist among these or any of them". All that places the onus of protection of the components of environment defined above.

This EIA study was thus carried out within the frame work of both Local, National, and International environmental guidelines and regulations, and also taking into account national and international documents concerning health, safety and social issues. The following documents were assumed as reference for the present study:  Guidance on EIA, EIS review, June 2001, European Commission;  Equator Principles, June 2013, Equator Principles Association;  International Finance Corporation (IFC) Sustainability Framework, 2012 Edition, Performance Standards;  Environmental, Health and Safety Guidelines, April 30 2007, World Bank and IFC;  Environmental, Health and Safety Guidelines for Nitrogenous Fertilizer production, April 30 2007, World Bank and IFC;  EIA Act 86 of 1992, Federal Environmental Protection Agency of Nigeria;  EIA Procedural Guidelines, 1995, Federal Environmental Protection Agency of Nigeria;  EIA Sectoral Guidelines, Oil and Gas Industry Projects, Sub-sectoral Guidelines for Petrochemicals, 1995, Federal Environmental Protection Agency of Nigeria;  EIA Sectoral Guideline, Manufacturing Industry, 1995.

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1.8.2 Applicable Legislative/Administrative Framework of the Project 1.8.2.1 International Legislations Nigeria is signatory to several laws, treaties and regulations that govern the environment. Among those applicable to the proposed project are:

Convention on Biological Diversity (1992) The objectives of the convention include the conservation of biological diversity, the sustainable use of its components and the fair and equitable sharing of benefits arising out of the utilization of genetic resources.

Basel Convention on the control of Trans-boundary Movements of Hazardous Wastes and Their Disposal (1987) The convention focuses attention on the hazards of the generation and disposal of hazardous wastes. The convention defines the wastes to be regulated and control their trans-boundary movement to protect human and environmental health against their adverse effects.

Convention on the Conservation of Nature and Natural Resources, 1968. This convention came into force in Nigeria on 7th May, 1974. The objectives of the convention is to encourage individual and joint action for the conservation, utilization and development of soil, water, flora and fauna for the present and future welfare of mankind, from an economic, nutritional, scientific, educational, cultural and aesthetic point of view.

Convention on Wetland of International Importance, Especially as Water Flow Habitat (1971). This provision came into force in Nigeria on 2nd February, 2001 with the objectives to stem the progressive encroachment and loss of wetlands now and in the future, recognizing the fundamental ecological functions of wetlands and their economic, cultural, scientific and recreational value.

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Montreal Protocol on Substances that Deplete the Ozone Layer, 1987 (As Amended) The objective of the convention is to protect the ozone layer by taking precautionary measure to control global emissions of substances that deplete it.

Convention on the Protection of Workers against Occupational Hazards in the Working Environment Due to Air Pollution, Noise and Vibration, Geneva, 1977. This convention is aimed at protecting workers against occupational hazards in the working environment.

Convention on Occupational Safety and Health and the Working Environment, Geneva, 1981. The objective of the convention is to prevent accidents and injury to health by minimizing the causes of hazards inherent in the working environment.

Convention on Safety in the Use of Chemical at Works, Geneva, 1990. The convention has the objective of enhancement of the existing legal framework for occupational safety regulating the management of chemicals at the work place with the broad purpose of protecting the environment and the public, and with the specific objective of protecting workers from harmful effects of chemicals.

World Bank Guidelines on Environmental Assessment (EA) 1991 The World Bank requires the execution of an EA on a proposed industrial activity by a borrower as a pre-requisite for granting any financial assistance in form of loans.

The World Bank Operational Policy – OP 4.01 states that the bank requires environmental assessment (EA) of projects proposed for Bank financing to help ensure that they are environmentally sound and sustainable, and thus to improve decision making. Additionally, the policy specify that the Bank undertakes environmental screening of each proposed project to determine the appropriate extent and type of EA.

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International Finance Corporation (IFC) Performance Standards IFC’s Sustainability Framework (International Finance Corporation, World Bank Group) articulates the Corporation’s strategic commitment to sustainable development, and is an integral part of IFC’s approach to risk management. The Sustainability Framework comprises IFC’s Policy and Performance Standards on Environmental and Social Sustainability, and IFC’s Access to Information Policy.

The Policy on Environmental and Social Sustainability describes IFC’s commitments, roles, and responsibilities related to environmental and social sustainability. IFC’s Access to Information Policy reflects IFC’s commitment to transparency and good governance on its operations, and outlines the Corporation’s institutional disclosure obligations regarding its investment and advisory services.

The Performance Standards are directed towards clients, providing guidance on how to identify risks and impacts, and are designed to help avoid, mitigate, and manage risks and impacts as a way of doing business in a sustainable way, including stakeholder engagement and disclosure obligations of the client in relation to project-level activities.

In the case of its direct investments (including project and corporate finance provided through financial intermediaries), IFC requires its clients to apply the Performance Standards to manage environmental and social risks and impacts so that development opportunities are enhanced.

IFC uses the Sustainability Framework along with other strategies, policies, and initiatives to direct the business activities of the Corporation in order to achieve its overall development objectives. The Performance Standards may also be applied by other financial institutions.

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Together, the eight Performance Standards establishes that the client is to meet throughout the life of an investment by IFC. These are:  Performance Standard 1: Assessment and Management of Environmental and Social Risks & Impacts  Performance Standard 2: Labour and Working Conditions  Performance Standard 3: Resource Efficiency and Pollution Prevention  Performance Standard 4: Community Health, Safety, and Security  Performance Standard 5: Land Acquisition and Involuntary Resettlement  Performance Standard 6: Biodiversity Conservation and Sustainable Management of Living Natural Resources  Performance Standard 7: Indigenous Peoples  Performance Standard 8: Cultural Heritage Full notice of the requirements of these standards were taken during preparation of the ESIA.

The IFC Environmental, Health and Safety (EHS) Guidelines The EHS guidelines (1991 and updated in 2007) are a set of technical reference materials that provide pollution related limits and standards that are acceptable to the IFC. In general, the guidelines seek to avoid, minimize and control environmental, health and safety (EHS) impacts during the construction, operation and decommissioning phase of a project or facility.

Equator Principles (June, 2013) The objective of the Equator Principles (EP) is to provide a financial industry benchmark for determining, assessing and managing environmental and social risk in project financing. The conditions under which The Equator Principles Financial Institutions (EPFIs) will provide loans to projects are summarized in Principles 1-10 below.

Principle 1: Review and categorization: As part of the EPFI's internal social and environmental review and due diligence, the EPFI will categories each project based on the magnitude of its potential impacts and risks, in accordance with the environmental

Chapter One: Background Information 1-12 IEFCL -Train2 Fertilizer Project EIA Report and social screening criteria of the International Finance Corporation (IFC) (Exhibit I of EP).

Based on these criteria (Exhibit I of the EP), the proposed project is considered a category B, as there are ‘potential limited adverse social or environmental impacts that are few in number, generally site- specific, largely reversible and readily addressed through mitigation measures’.

Principle 2: Social and Environmental Assessment: For a project classified as category A or B, the borrower should carry out a Social and Environmental Assessment ("Assessment") which addresses all relevant social and environmental risks of the project. The Assessment may address, if relevant, the illustrative list of issues described in Exhibit II, which includes the following items: a) Assessment of baseline environmental and social conditions; b) Consideration of feasible environmentally and socially preferable alternatives; c) Requirements under host country laws and regulations, applicable international treaties and agreements; d) Protection and conservation of biodiversity (including endangered species and sensitive ecosystems in modified, natural and critical habitats) and identification of legally protected areas; e) Sustainable management and use of renewable natural resources (including sustainable resource management through appropriate independent certification systems); f) Use and management of dangerous substances; g) Major hazards assessment and management; h) Efficient production, delivery and use of energy; i) Pollution prevention and waste minimization, pollution control (liquid effluents and air emissions), and solid and chemical waste management; j) Viability of Project operations in view of reasonably foreseeable changing weather patterns/climatic conditions, together with adaptation opportunities; k) Cumulative impacts of existing projects, the proposed project, and anticipated future projects;

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l) Respect of human rights by acting with due diligence to prevent, mitigate and manage adverse human rights impacts; m) Labour issues (including the four core labour standards), and occupational health and safety n) Consultation and participation of affected parties in the design, review and implementation of the project. o) Socio-economic impacts p) Impacts on affected communities and disadvantaged or vulnerable groups q) Gender and disproportionate gender impacts r) Land acquisition and involuntary resettlement s) Impacts on indigenous peoples and their unique cultural systems and values t) Protection of cultural property and heritage u) Protection of community health, safety and security (including risks, impacts and management of Project’s use of security personnel) v) Fire prevention and life safety

Note: As mentioned in Exhibit II of the Equator Principles, the above list of issues is for illustrative purposes only. The Assessment process of each project "may or may not identify all issues noted above, or be relevant to every project" (Equator Principles, July 2013). The Assessment should also propose mitigation and management measures appropriate to the nature and scale of each specific project.

Principle 3: Applicable Environmental and Social Standards: For projects located in non- Organization for Economic Co-operation and Development (OECD) countries (including Egypt), and those located in OECD countries not designated as High-Income, as defined by the World Bank Development Indicators Database, the Assessment should also refer to the then applicable IFC Performance Standards (Exhibit III of the EP) and the then applicable Industry Specific Environmental Health and Safety Guidelines ("EHS guidelines") (Exhibit III of the EP). For all projects, the assessment process should address compliance with relevant requirements of host country laws, regulations, and permits pertaining to social and environmental matters.

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Principle 4: Environmental AND Social Management system and Equator Principles Action Plan: For all Category A and Category B projects located in non- OECD countries, and those located in OECD countries not designated as High-Income, as defined by the World Bank Development Indicators Database, the borrower should develop or maintain an Environmental and Social Management Plan (ESMP), which addresses the relevant findings and draws on the conclusions of the Assessment. The ESMP should describe and prioritize the actions needed to implement mitigation measures or corrective actions, and monitoring measures necessary to manage the impacts and risks identified in the Assessment. Borrowers will build on, maintain or establish a Social and Environmental Management System (ESMS) that addresses the management of impacts, risks, and corrective actions.

Principle 5: Stakeholder Engagement: For category A and, as appropriate, category B projects located in non-OECD countries, and those located in OECD countries not designated as High-Income, as defined by the World Bank Development Indicators Database, the government, borrower or third party expert should consult with project affected communities and where relevant, Other Stakeholders, in a structured and culturally appropriate manner. The Assessment documentation and ESMP or a non- technical summary thereof, should be made available to the public by the borrower for a reasonable minimum period in the local language and in a culturally appropriate manner. The borrower should take account of and document the process and results of the consultation, including any actions agreed resulting from the consultation.

Principle 6: Grievance Mechanism: For category A and, as appropriate, category B projects located in non-OECD countries, and those located in OECD countries not designated as High-Income, as defined by the World Bank Development Indicators Database, to ensure that consultation, disclosure and community engagement continues through construction and operation of the project, the borrower will establish appropriate procedures in order to receive and address concerns or grievances about the project’s social and environmental performance.

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Principle 7: Independent Review: For all Category A and, as appropriate for Category B projects, an independent social or environmental expert not directly associated with the borrower should review the Assessment Documentation including the ESMPs, the ESMS and the Stakeholder Engagement process documentation in order to assist EPFI's due diligence, and assess Equator Principles compliance. Principle 8: Covenants: An important strength of the Principles is the incorporation of covenants linked to compliance. For all Category A and Category B Projects, the borrower will covenant to: a) Comply with all relevant host country social and environmental laws, regulations and permits; b) Comply with the ESMPs and Equator Principles AP (where applicable) during the construction and operation of the Project in all material respects; c) Provide regular reports in a format agreed with EPFIs on compliance with the ESMPs and Equator Principle AP (where applicable), and on compliance with the relevant local, state and host country social and environmental laws, regulations and permits; and d) Decommission the facilities in accordance with an agreed Decommissioning Plan (where applicable). The level of detail contained in a decommissioning plan (where necessary) will depend on the identified impacts and risks of the project (please refer to quote below):

“The Action Plan may range from a brief description of routine mitigation measures to a series of documents (e.g., resettlement action plan, indigenous peoples plan, emergency preparedness and response plan, decommissioning plan, etc). The level of detail and complexity of the Action Plan and the priority of the identified measures and actions will be commensurate with the project's potential impacts and risks” (Equator Principles, 2013)

Where a borrower is not in compliance with its social and environmental covenants, EPFIs will work with the borrower to bring it back into compliance to the extent feasible, and if the borrower fails to re-establish compliance within an agreed grace period, EPFIs reserve the right to exercise remedies, as considered appropriate.

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Principle 9: Independent Monitoring and Reporting: To ensure ongoing monitoring and reporting to EPFIs over the life of the loan, EPFIs will, for all Category A projects, and as appropriate, for Category B projects, require appointment of an independent environmental and/or social expert or require the borrower to retain qualified external experts to verify its monitoring information.

Principle 10: Reporting and Transparency (EPFI reporting): Each EPFI adopting the Equator Principles commits to report publicly at least annually about its Equator Principles implementation processes and experience, taking into account appropriate confidentiality considerations.

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1.8.2.2 National Laws / Programme Sr. Regulatory Objective Relevant Provision Regulator No. Instrument 1. Environmental To ensure that before any  The public or private sector of the economy is forbidden FMENV Impact Assessment decision is taken to undertake or from undertaking, embarking or authorizing projects or Act, 86 of 1992 authorize the commencement activities without prior consideration, at an early stage, of of any activity likely to impact their environmental effects. on the environment by any  Where the extent, nature or location of a proposed project person, authority, corporate or activity is such that it is likely to cause significant effect body or unincorporated body on the environment, its Environmental Impact Assessment including the Government, shall be undertaken in accordance with the provision of Federal, State or Local, that the the Act. environmental effects of such  Non-compliance with the Act will attract a fine of One activity shall first be taken into Hundred Thousand Naira (N100,OOO.OO) or five years account. imprisonment in the case of an individual and in the case of a corporation a fine of not less than fifty thousand Naira (N50,OOO.OO) and not more than one hundred thousand Naira (N100,OOO.OO).

2. S. I. 8 National Regulation of effluents discharged  Every industry is to install anti-pollution equipment for the FMENV Environmental into the environment by Industries detoxification of effluent and chemical discharges Protection (Effluent in Nigeria. emanating from industries. Limitation)  The anti-Pollution equipment should be based on the Best Regulations 1991. Available Technology (BAT), the Best Practicable/technology (BPT) or the Uniform Effluent Standards (UES).

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Sr. Regulatory Objective Relevant Provision Regulator No. Instrument  Waste Water parameters to be monitored are as follows: – Ammonia, Chloride, Chromium, Nitrate, Sulphate, Suspended Solids, Urea, , Zinc, Calcium, COD, BOD, Iron, Copper, Oil & Grease, pH, Phosphate, , Temperature and Total Dissolved Solids. 3. S. I. 9 National Prohibition of industry or facility  An industry or facility shall; (a) have a pollution-monitoring FMENV Environmental from the release of hazardous or unit within its premises; (b) have on site a pollution control; Protection (Pollution toxic substances into the air, water or (c) assign the responsibility for pollution control to a Abatement in or land of Nigeria’s ecosystem person or body corporate accredited by FMENV. Industries and beyond limits approved by  A discharge, including solid, gaseous and liquid waste from Facilities Generating FMENV. any industry or facility shall be analyzed and reported to the Wastes) Regulations nearest office of FMENV every month, through a discharge 1991. Monitoring Report.  An industry or a facility shall setup machinery for combating pollution hazard and maintain equipment in the event of an emergency.  Engaging in the storage, treatment and transportation of harmful toxic wastes within Nigeria without a permit issued by FMENV prohibited.  An industry or a facility which is likely to release gaseous, particulate, liquid or solid untreated discharge shall install, into its system, appropriate abatement equipment in such manner as may be determined by FMENV.

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Sr. Regulatory Objective Relevant Provision Regulator No. Instrument  No effluent with constituents beyond permissible limits shall be discharged into public drains, rivers, lakes, sea or underground injection without permit issued by FMENV.  Industry forbidden from exposing an employee to any hazardous condition in his workplace.  FMENV shall demand environmental audits from existing industries and Environmental Impact Assessment from new industries and major development projects

4. S. I. 15 National Management of solid and  All industries or facility to inform the FMENV of all toxic, FMENV Environmental Hazardous Wastes in Nigeria. hazardous and radioactive substances, which they discharge Protection during their production processes. Management of Solid and Hazardous Wastes Regulations 1991.

5. Harmful Waste Prohibition of the carrying,  All activities relating to the purchase, sale, importation, FMENV (Special Criminal depositing and dumping of transportation, deposit, storage of harmful waste prohibited Provisions, etc.) Act harmful waste on any land or and declared unlawful. 1988. L.F.N. 1990. territorial waters.  The carrying on of the above activity without lawful authority is criminal and shall attract an imprisonment for life and forfeiture of carrier object etc.

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Sr. Regulatory Objective Relevant Provision Regulator No. Instrument  Harmful Waste means any injurious, poisonous, toxic or noxious substance and, particular, includes nuclear waste emitting any radioactive substance if the waste is in such quantity, whether with any other consignment or the same or different substances, as to subject any person to the risk of death, fatal injury or incurable impairment of physical and mental health; and the fact that the harmful waste is placed in a container shall not by itself be taken to exclude any risk which might be expected to arise from the harmful waste. 6. Factories Act, 1990. To provide for the registration of  Factory to provide healthy facilities for workers and ensure Director of factories. the health of workers. factories of To make adequate provisions  Workers welfare should be priority of factory. the regarding the safety of workers.  Director of Factories to be informed of accidents and Federation, industrial diseases. Inspectors of Factories. 7. Criminal Code, 1990 Prevention of environmental  Contamination of water, Stream, spring, Well, Tank, Nigeria Police crime Reservoir prohibited and punishable with an imprisonment Force. for six (6) months.  Vitiation of atmosphere and spread of infectious disease prohibited and punishable

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Sr. Regulatory Objective Relevant Provision Regulator No. Instrument 8. Land use Act Cap Land administered for the use  All land in urban areas shall be under the control and Relevant 202, 1978. and common benefit of all management of the Governor of each State. Agency in Nigerians. State

9. Constitution of the Provides, inter alia, the  The State shall protect and improve the environment and 1 Federal Republic of “Fundamental Objectives and safeguard the water, air and land, forest and wild life of Nigeria (CFRN, Directive Principles of State Nigeria. (CHAP. II, Section 20 – CFRN, 1999). 1999). Policy” (CHAP. II – CFRN, 1999).

10. Federal government To provide enabling environment  Create agricultural extension services in all state ministries Ministry of green revolution for improved agriculture. of agricultural. Agriculture programme, 1980 To provide necessary chemical  Establish a division in the ministry to support state inputs & mechanical equipment agricultural development program. to farmers.  Establish a division of ministry to coordinate funding from donor agencies. 11. Federal gas To optimize the advantage of the  To provide the necessary infrastructures development for Minister of revolution abundance of natural gas to capitalizing the nation’s gas resources Petroleum programme, 2011 positively impact on the lives of  To ensure sustainable electricity delivery for domestic and present and future generations of industrial uses. the Nigerian citizens  Accelerate industrialization by providing cheaper, safer, cleaner and environmentally friendly fuel to industries in the region.  By 2014 to position Nigeria firmly as the undisputed regional

1 General Abdusalami promulgated the Constitution in early May 1999

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Sr. Regulatory Objective Relevant Provision Regulator No. Instrument hub for natural gas-based industries as fertilizer, and petrochemicals.

12. National Regulations focused on the  Section 7 provides authority to ensure compliance with NESREA Environmental protection and sustainable environmental laws, local and international, on Standards And development of the environment environment sanitation and pollution prevention and Regulation and its natural resources. control through monitory and regulatory measures; Enforcement Agency  Section 8(1) (k) empowers the agency to make and review (NESREA) Act And regulations on air and water quality, effluent limitations, Regulations: control of harmful substances and other forms of 2009 -2011 environmental pollution and sanitation;  Section 27 prohibits, without lawful authority, the discharge of hazardous substance into the environment. This offence is punishable under this section, with a fine not exceeding One Million Naira (1,000,000) and an imprisonments term of five (5) years. In the case of a company, there is an additional N 50,000 for every day the offence persists.

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Sr. Regulatory Objective Relevant Provision Regulator No. Instrument 13. National Regulations NESREA Environmental Standards And  National Environmental To ensure construction activities conducted in an environmental Regulation (Construction Sector friendly manner Enforcement Agency Regulations), 2011 (NESREA) Act And  National Environmental (Control To ensure prevention and control of vehicular emission. Regulations: of Vehicular Emissions from 2009 -2011 petrol and Diesel Engines) Regulations, 2011  National Environmental (Surface To ensure protection and pollution of surface and ground water and Ground Water Quality quality. Control) Regulations, 2011

 National Environmental To ensure protection of the environment against house- (Sanitation and Waste Control) keeping, waste generation and disposal. regulation 2009

 National Environmental (Ozone To protect the environment against Ozone depleting Layer Protection) Regulations substances. 2009 To prevent the production, use, importation or sale of Ozone depleting substances.

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Sr. Regulatory Objective Relevant Provision Regulator No. Instrument  National Environmental To provide for the wise use of wetlands and their resources; (Wetlands, River Banks and Lake Shores Protection) Regulations, 2009

 National Environmental (Noise Prescribe maximum permissible noise levels. Standards and Control) Provide for the control of noise and mitigation measures for the Regulations, 2009 reduction of noise. Ensure maintenance of healthy environment and psychological well-being of the people.

 National Environmental Issuance of permits and licenses to protect the environment (Permitting and Licensing from degradation and pollution Systems) Regulations, 2009

 National Environmental (Air The regulation provides control and mitigation measure with Quality Control) regulations, respect to company’s operational influence to ambient air 2014 quality of their immediate through setting up of regulatory limit and criteria to check their activity influence to ambient air.

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1.8.2.3 State Laws Sr. Regulatory Objective Relevant Provision Regulator No. Instrument 1. Rivers State  Environmental Protection,  Power to establish specific environmental standards and Rivers State Environmental biodiversity conservation and guidelines. Ministry of Protection Agency sustainable development of  Power to inspect Industries. Environment Edict Number 2 1994 Rivers State’s Natural  ‘Polluter pays’ principles. Resources.  Any actor that pollutes must report within 48 hours to the  Establishment of standards and Ministry. guidelines.  Technology Development.  Monitor and Control Industrial and hazardous Wastes.  Collect effluent discharge fee.  Enforcement of Industrial and domestic sewage treatment. 2. Noise Control Edict,  Control of Noise Pollution in  Power to set noise standards for residential and industrial Rivers State 1985 the Port Harcourt Metropolis, areas. Ministry of and elsewhere in the State.  Power to prosecute violators of noise limits. Environment 3. Rivers State  Regulation of Polices and  Power to inspect homes, commercial and industrial outfits. Rivers State Environmental strategies aimed at promoting  Power to enforce sanitation policies. Environmental Sanitation Authority environmental hygiene  Power to seal outfit for violating sanitation and hygiene Sanitation Edict, 1986 sanitation and facilitating the rules. Authority disposal of refuse and other waste product.

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Sr. Regulatory Objective Relevant Provision Regulator No. Instrument 4. Pollution  The Edict required persons  Power to assess degraded /polluted sites. Director of Compensation Tax who are paid compensation as  Power to set fees and payment rates for items destroyed by Internal Edict, 1994 a result of damage to their land pollution events. Revenue and properties to pay a percentage of it to the Government coffers. 5 Rivers State Waste  The Agency mandate is to  To control waste generation, segregation/storage, disposal RIWAMA Management Agency develop a waste management and treatment using environmentally friendly and state-of- 2014 system for the state, generate the art technology implementable regulation to enforce sanity within the system. 6 Rivers State Interim  Regulate the generation,  The interim guidelines and standards on environmental Rivers State Guidelines and handling, storage, disposal and pollution control and management in Rivers State was Ministry of Standards on management of all wastes of established to protect, restore and preserve the ecosystems Environment Environmental whatever origin in Rivers State. of the State. Pollution Control and  Regulate physical development  “These guidelines and standards are set to ensure that management, 2010 (infrastructural, industrial, etc.) industrial activities and waste management practices are in compliance with the compatible with our overall goal of bequeathing a cleaner, principle of sustainable safer and therefore more prosperous environment to the development present generations of Rivers men, women, children and those yet unborn.”

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1.9 STRUCTURE OF THE REPORT The report shall conform to International standard and Federal Ministry of Environment reporting format which is summarized as follows:  Title Page  Table of Contents  List of Tables  List of Figures  List of Maps  List of Plates  List of Acronyms and Abbreviations  List of Preparers  Acknowledgement  Executive Summary Chapter One : Introduction; Background information, Administrative and Legal framework, Chapter Two : Project Justification, Chapter Three : Project Description, Chapter Four : Description of the biophysical, socio-economic and health Environment, Chapter Five : Associated and Potential Environmental Impacts, Chapter Six : Mitigation Measures, Chapter Seven : Environmental Management Plans, Chapter Eight : Conclusions and Recommendations References Appendices

1.10 Declaration IEFCL has proposed to embark on a fertilizer train 2 project adjacent to fertilizer train 1 plant. In the planning, construction, operational and decommissioning stages of this project IEFCL shall:  Comply with environmental regulations, laws, statues and edicts.  Adopt appropriate measures to mitigate, identified and predicted adverse environmental impacts arising from or associated with the project.

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CHAPTER TWO

PROJECT JUSTIFICATION

2.1 SITE JUSTIFICATION The Nitrogenous Fertilizer Plant (Urea), IEFCL-Train2 Project, constituted mainly the Ammonia and Urea Plant, will be sited in Indorama Eleme Fertilizer & Chemicals limited facility within Indorama complex. A thematic map of the study area can be found in Appendix 2.1. See also the drawing of the complex showing the relative positions of the proposed Ammonia and Urea plant. (Appendix 1.1).

The site has well established off-sites infrastructures and other related facilities for the project to support efficient operations. Other advantages that justify the sitting of the Ammonia and Urea plant in the existing Indorama complex includes: available land with proper soil conditions and a distance of about 15 km from Onne Port (that will be used and adequately equipped to market Urea Fertilizer product), with good marine conditions and limited influence from monsoon weather.

Site selection considered also the geographical and meteorological conditions of the location area (as will be described in chapter 4), in order to take into account any potential effect deriving from air inversion or trapping of pollutants and where prevailing winds are towards sensitive areas. A physical map of the study area, showing the relevant morphological features of the site (within a range of 5 km radius), can be found in Appendix 2.2.

2.2 NEED The gross imbalance in the supply and demand of fertilizer for agricultural productivity in Nigeria goes to support the need for expansion of existing fertilizer plant.

The recent Federal Governments Gas revolution policy (See Chapter 1, paragraph 1.6.2.3) which authoritatively orders the use of gas for the setting up of fertilizer plants in various parts of the country amongst other uses emphatically supports the need for this project.

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Natural gas apart from supplying energy for power has found uses in agricultural and manufacturing sectors to realize the objective of the unsuccessful “Green Revolution” (See Chapter 1, paragraph 1.6.2.3) thereby contributing to the food security and quality of life for the population, reduction of greenhouse gases into the atmosphere and global warming. The project will improve the use of nation’s gas resources thereby avoiding wastage of natural resources that contributes to greenhouse gas emissions resulting to global warming.

Natural gas is the primary raw material for the production of ammonia and resultant carbon dioxide for production of urea fertilizer. The use of associated gas by the Train2 project which either to flared from the oil production fields will now be another beneficial attempt to reduce gas flaring.

According to Central Bank of Nigeria, Energy Market Analysis for October 2015, Nigeria's gas reserve is approximately 187 tcf (trillion cubic feet), as such Nigeria, is described as a gas province. Although Nigeria is blessed with abundant gas resources, not much of it has been harnessed, with the nation's primary focus being on crude oil production. The domestic gas market is generally under developed with a record of high gas flaring and a significant percentage of available natural gas being exported as liquefied natural gas.

According to NNPC monthly financial and operation report for July 2017, monthly gas production is at 245.66 Billion Cubic Feet (BCF) translating to average daily production of 8.1BCF, while the natural gas consumption rate of the new fertilizers plant is at 89,600,000 cubic feet of gas per day (about 0.09 BCF)1, which would cut down on quantity to be released to the environment through gas flaring.

From the period of July 2016 to July 2017, a total of 2,878.49 BCF of gas was produced representing an average daily production of 7,271.08 mmscfd during the period, distributed among Joint Ventures (JVs) 67.87%, Production Sharing Contracts (PSCs) 24.21% and NPDC 7.92% (see Table 2.1).

1 Natural gas consumption including Fertilizer production (included auxiliary boiler and extra power generation) needs.

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Table 2.1 Monthly National Gas Production in BCF and mmscfd

Figure 2.1 Average daily National Gas production in mmscfd

In Nigeria, use of fertilizer in the year 2016 was estimated at 12.6 kg/ha (FMARD 2016) slightly above sub Saharan average of 9 kg/ha but much below the 200 kg/ha recommended by the United Nations Food and Agriculture Organization (FAO). Over- dependence on external supply was brought about by the substantial availability of budgetary resources to support imports and overvaluation of the local currency in the past. During the late 1980s and mid-1990s, domestic fertilizer production of the total supply varied between 46 and 60 percent (Ogunfowora 1993 cited in Phillip et al. 2009).

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The situation deteriorated, in the early 2000s as all the nitrogen phosphorous & potassium (NPK) fertilizers used in Nigeria was imported in the absence of any domestic production as a result of the closure of the only producing plant, the National Fertilizer Company of Nigeria (NAFCON) for repairs. From 2006 to 2008 production trickled in but was still below consumption required per hectare of land. In 2008, 370,676MT of nitrogen, 60,793MT of Phosphate and 40,428 MT of Potash, types of fertilizers were imported as against local production of 12,500MT of Nitrogen, 6,500 MT of phosphate and 6,800 MT of Potash types of fertilizers. This disparity in local production and importation affected fertilizer consumption in kg/hectare of arable land in Nigeria (See Table 2.1). Adesina (2008) observed that soil nutrient mining is killing Africa particularly in Nigeria where more than 60kg/ha of nutrient loss was recorded in 1995-1997 & 30- 60kg/ha in 2002 -2004. A major reason for the high soil nutrient deficiency is low level of fertilizer use in Africa compared to the rest of the world. Adesina (2008) viewed fertilizer as a “Golden Bullet” to rapid agricultural growth.

Therefore, the domestic production of Nitrogenous fertilizer from both IEFCL Train1 and Train2 projects will add value to the need for adequately addressing the low fertilizer consumption scenario of the country.

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Table 2.2: Fertilizer production, import, and consumption in Nigeria 2002-2017

Fertilizer type Element 2002 2003 2004 2005 2006 2007 2008 2009 2010 2011 2012 2013 2014 2015 2016

Nitrogen fertilizers (N total 0 0 3,800 4,868 20,821 12,505 0 54743 31998 65940 369910 235000 170000 281750 695000 nutrient) Production Phosphate fertilizers (P205 quantity in 0 0 2,200 2,779 12,540 6,553 0 24108 5100 5738 6376 6440 6440 611 total nutrient) nutrient (tones of nutrient) Potash fertilizers (K20 total 0 0 2,450 3,066 14,314 6,803 0 0 0 0 0 0 0 0 0 nutrient)

Ammonium nitrate 2,849 2,437 0 0 0 0 83199 54955 1013 4927 1319 66 36 0 0 Ammonium sulphate 4,709 517 74,420 76,490 78,619 24,260 4622 5496 25455 132 11417 12391 4181 11804 27679 Diammonium phosphate 5,009 466 0 0 0 19532 24438 49 0 0 0 0 200 5500 5250 (DAP) Monoammonium phosphate 219 20 30,000 25,000 22,000 0 19571 0 0 0 6612 1462 33 29 49 (MAP) Import quantity 97,60 NPK complex > 10kg (MT) 25,770 0 0 0 0 12800 0 0 0 231000 295000 345000 165000 380455 5 Potassium chloride (Muriate 2,946 10,810 11,000 10,000 11,000 12,219 8663 0 16825 21834 35374 14640 22188 7484 4165 of potash)

Superphosphate other 0 0 8,000 10,000 11,000 14,718 0 0 0 20000 0 22682 0 16200 16600 288,2 Urea 77,207 39,000 417,900 306,900 75,864 1400 8000 370000 120000 100434 598616 291966 120455 21013 52 Nitrogen fertilizers (N total 94,40 137,60 39,000 211,047 160,104 43,508 141000 45000 240000 85000 100000 352782 175000 61 1370 nutrient) 0 3 Import quantity in Phosphate fertilizers (P205 41,40 nutrients (MT of 49,432 17,040 14,800 13,240 11,634 64000 12000 67000 36000 56000 78000 51000 1320 24040 total nutrient) 0 nutrients) Potash fertilizers (K20 total 30,40 42,712 6,600 6,000 6,600 7,331 78000 16000 68000 43000 74000 57000 41203 1582 499 nutrient) 0 Fertilizer Consumption in All 4.53 6.4 4.55 7.2 10.04 4.21 5.88 5.26 12.21 6.56 11.38 17.8 10.9 12.66 17 kg-ha of arable land

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From the graphical illustrations in the figure 2.3 below, it can be deduced that the dependence on foreign imported urea fertilizer in to Nigeria dropped drastically from 2016 owing to the coming on-stream of the IEFCL Train1 plant, which will further be consolidated by the proposed IEFCL-Train2 project.

Fig 2.1 Fetilizer production in nigeria from 2002 to 2016

Fig 2.2 Fetilizer consumption in kg-ha of arable land 2002 to 2016

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Fig 2.3 Fetilizer importation in nigeria from 2002 to 2016

Fig 2.4 Fetilizer import quantity nutrients (MT of nutrients) in nigeria from 2002 to 2007

The arable urea outlook also favors the need for Nigeria to endeavor to share in the global market. Urea is widely used in Nigeria as fertilizer product because it’s high “N” nutrient content. It is used in blending to form other types of fertilizer. Most of these plants will be found in China, India, Iran and Latin America. The demand for urea fertilizer is growing in

Chapter Two: Project Justification 2-7 IEFCL -Train2 Fertilizer Project EIA Report developing countries as well due to population growth, changes in per capita income, food preferences and increase in food prices.

The above information emphasizes how essential and necessary this project is, as it will help to solve the urgent need for a strategic investment program to increase the availability and use of fertilizer in the much needed Green Revolution in Nigeria that will usher in food security for Nigeria in the long term.

2.3 VALUE The fertilizer project will help to improve the share of agriculture in Nation’s Gross Domestic Product (GDP). Agriculture, a dominant sector in the Nigerian economy since 1960’s, engages about 70% of the population directly and provides more than 75% of non-oil foreign exchange earnings (IEFCL Market Survey, 2010). In 1960s, the agricultural sector used to be the most important sector in terms of contribution to domestic production, employment and foreign exchange earnings. However, due to non-availability of fertilizer, poor crop yields led to agriculture being uneconomical. As a result, the land under cultivation has been reducing over the years.

The agriculture sector of Nigerian economy, however, contributes significantly to rural employment, food security, non-oil foreign exchange earnings and industrial raw materials, with the largest share of about 22.97% real GDP in Quarter 2 2017 (National Bureau Statistics ).

The trend in the share of agriculture in the GDP shows a substantial variation and long-term decline from 60% in the early 1960s through 48.8% in the 1970s and 22.2% in the 1980s. In 1993 (at 1984 constant factor cost) crops, the major source of food in Nigeria, accounted for a share of around 30% of the GDP (IEFCL Market Survey, 2010).

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For the future, it is noticeable that considering a moderate growth rate of 2%, the population will reach 240 million by 2030, thereby at least doubling the food demand (IEFCL Market Survey, 2010).

At the moment the majority of population dependent on agriculture currently lives below the poverty line due to very poor land yields. Provision of fertilizers at affordable prices will help to achieve higher yields to meet the demands of growing population as well as to uplift large part of the population out of poverty.

The following reasons are limiting the use of fertilizers in Nigeria:  Higher price  Low fertilizer Quality  Non-availability of fertilizer at times due to complete dependence on imports  High cost of credit & transport  Lack of proper education and information with the farmers.

As such and to keep pace with population’s growth rate, Nigeria requires a high investment/growth rate policy for agricultural sector, the key element for which is an efficient functioning of the fertilizer sector.

The investment by IEFCL Management to set up one more facility for the production of 2300 MTPD Ammonia and 4000 MTPD Urea at its existing facility at Port Harcourt (Rivers State, Nigeria) will help improve domestic production, reduce importation, enhance supply/distribution networks and provide new employment opportunities for the growing job demand of young Nigerian population.

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2.4 SUSTAINABILITY 2.4.1 Technical Sustainability The proposed project is expected to be technically sustainable because of the proven technology from international technology licensors employed in the Train1 facilities which are already in operation. Train2 project will be a replica of the Train1 plant. The Train1 plant has also proven to be economically viable, with a minimal environmental, social and health impacts to personnel and the environment.

Strict adherence to internationally accepted engineering design and construction standards as well as codes of practice that shall be adopted at all stages of the project are expected to ensure technical sustainability. The availability of technically competent human resources existing in Train1 assures the project sustainability as well as justifying the venture. Fertilizer production is a continuous process that requires no interruptions during operations either by gas or power supply. Thus, the high abundance of raw material (natural gas) available in Nigeria which is used as feed stock and also for power generation along with the technical know-how to operate the plant guarantees the sustainability of this project.

2.4.2 Environmental Sustainability Incorporation of the recommendations of this ESIA at the appropriate stages of the project development is expected to ensure that the proposed Fertilizer plant is environmentally sustainable. In addition, strict adherence to the EMP shall ensure that every aspect of the proposed project is sustainable with minimal impact, especially as it concerns the natural environment and the people who inhabit it.

2.4.3 Social Sustainability The need for the activity is borne out of IEFCL commitment to meet the ever increasing demand of Fertilizer nationwide to achieve food security and to create employment opportunities. The robust and all inclusive engagement of the host communities by IEFCL Management has endeared the project to the heart of the Chiefs, Elders, Opinion leaders,

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Youth and Women of the host communities. This is evidence of the positive social acceptability of the project.

2.4.4 Economic Sustainability The location and abundance of the major feed, capitalizing on Nigeria’s competitive advantage in the form of gas reserve, ensures that the fertilizer plants will count on available resources. The availability of proficient manpower, the presence of a well- structured industrial area and the choice to realize a production (Nitrogenous Fertilizers) based on proven technology are further elements in favor of the business venture.

One other distinct advantage of this project which will surely ensure its sustainability is the fact that it will help to correct the imbalance in the supply and demand of urea fertilizer creating an enduring market.

Presently the per capita consumption of fertilizer is very low in Africa, and Nigeria in particular. The projection that the use of fertilizer per hectare should rise up to 50 kg/ha in 2015 from 13 kg/ha in 2009 gives it the enabling environment for sustainability. Moreover, the dependence of Nigeria on the importation of fertilizer (as showed in Table 2.1) further boosts the need of a more secured internal supply/distribution network.

Referring to the above, the project will improve the following areas of the economy: I. The local economy and development of other downstream medium scale cottage industries like fertilizer blending plants; II. Direct & indirect employment of local population; III. Substantial indirect employment for plant construction, transportation and support services.

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2.5 PROJECT ALTERNATIVES / OPTIONS The availability of reliable source of the feedstock (Natural gas), well-endowed project site with all the resources required for a steady production of fertilizer, limited the considerations for site and production alternatives. The evaluation of alternate raw material such as coal, concluded that such options will not be economically viable. In view of this fact, availability of raw material and location assumed the critical factors. Alternative site for the factory or the use of alternative raw material which call for different manufacturing technologies would have stretched environmental safety, engineering technology and logistic requirements with concomitant high economic cost for design, engineering and construction.

Consequently, the decision arrived at choosing the option with the best site alternative, easy raw material availability and tested technical sustainability.

The following paragraphs therefore describe the alternatives and the reasons considered in selecting such options. The technological solution has been adopted as a consequence of the raw material selected. The “No project alternative” is finally discussed into a dedicated paragraph.

2.5.1 Option 1: Natural Gas as Raw Material The usage of natural gas as major feed for the production of Ammonia and Urea was considered more cost beneficial and environmentally friendly than the usage of other raw materials, such as coal and biomass, in these respects: i. The natural gas will be available at the plants battery limit. A separate authorization is in place to assure the delivery of such raw material; ii. The reserve of the natural gas will suffice well above the life cycle of the plants;

iii. Natural gas is cleaner during breakdown to the useable components of CO2, H2 than Coal or Biomass;

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iv. Coal or Biomass as major raw material for the project would be capital intensive because of the cost of trucking or transporting coal from the nearest commercial deposit (Enugu) to Project site in Eleme; v. The environmental cost that would be incurred from the processing of coal or Biomass as raw material would be very uncompetitive. As a matter of fact, use of coal or biomass as feed for production of fertilizer would have more environmental implications, concerning in particular air pollution and residual waste management; vi. The option of using coal or biomass would also demand land take, which can bring to loss of vegetation, biodiversity and other natural resources. vii. Finally, if coal or biomass would be used as raw material, the engineering task and cost in developing the site for process units, utilities, waste water treatment, and offsite would be more significant.

2.5.2 Option 2: Use of Indorama Complex as Project Location Locating the project in the existing Indorama Complex has numerous positive advantages over the acquisition of a virgin land based on the following reasons: i. Land acquisition and associated socio-economic disadvantages would not be an issue, if the project is sited within the existing Indorama complex; ii. The engineering tasks and cost involved in preparing a new virgin land are not necessary and required.

Choosing the Indorama complex as Fertilizer plant site is also advantageous since it is already endowed with power, water, wastewater treatment facilities, storage facilities, adequate and available manpower and technology.

2.5.3 No Project Alternative This option as the title imply involves abandoning the idea of building the new plants. This option is anti-development as well as been detrimental to the nation’s policy on Agriculture, and Food Security in addition to national economy. It will perpetuate the situation where

Chapter Two: Project Justification 2-13 IEFCL -Train2 Fertilizer Project EIA Report importation of the urea will be the only means of satisfying our agriculture and chemical industrial sectors. The no-project option would also deny the host communities, the huge benefit of acquiring skills and empowerment. Consequently this option is not likely to be considered a valid alternative to the realization of the project.

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CHAPTER THREE PROJECT DESCRIPTION

3.1 INTRODUCTION IEFCL intends to build Train-2 Fertilizer Plant for Ammonia and Urea production. This chapter describes the location of proposed project, production process, plant’s product and information on various discharges, waste and emissions. The proposed project is located geographically Latitude 4049’N and Longitude 706’E within the Indorama complex on a piece of land of 26 hectares.

For identifying the location of the initiative, please refer chapter -1 Plate 1.1(Rivers State) and Plate 1.2. (Eleme Local Government) - Due to its location and expected effects (see Chapter 5 for details), the environment of other State, Local Government Area or areas outside Nigeria is not likely to be affected by the Train2 Fertilizer project.

3.2 PROPOSED LOCATION OF AMMONIA, UREA PLANTS In the following Table 3.1, permanent and temporary Fertilizer project components within the area of Indorama Complex are listed.

The attached Plot plan (Appendix 1.1) gives a graphic representation of the areas covered by the IEFCL-Train2 and associated auxiliary facilities identified in legends. The total land area covered by proposed IEFCL-Train2 project and associated auxiliary facilities will be approximately 26 hectors. A trial1 of photographical rendering provided in Appendix 3.1 shows the likely landscape appearance of site, which is expected after the realization of IEFCL-Train2 Fertilizer Plant. Site layout plan of Train-2 fertilizer plant is attached in Appendix 3.2

1 According to the available details of engineering design a trial of photographical rendering has been provided assuming reference of a similar plant for the production of Ammonia and Urea. These plants have been inserted in the IEPL/IEFCL site area foreseen by the Project. For more details see Appendix 3.1.

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Table 3.1: New permanent and temporary Project components

ID2 Particulars

A New Permanent Project components

20 Polisher, Waste water treatment and Air Dryer Units

29 Ammonia Plant

30 Urea Plant

31 Cooling Towers

32 Urea Warehouse for Bulk Storage

33 Urea Truck Loading facilities

34 Ammonia Storage facilities

35 Natural Gas (NG) Receipt Facilities

36 Raw Water and DM Water

37 Argon Recovery / Purge Gas Recovery Plant

38 Nitrogen plant

B New Temporary Project components (only for construction phase)

Temporary Office facilities; 39 Laydown, Pre-fabrication, Construction warehouse area

2 ID refers to the Legend Code in Appendix 1.1

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3.3 PROJECT DESCRIPTION The project as mentioned above entails the building of the following two Process plants to manufacture Ammonia & Urea:  Ammonia Plant : 2300 MTPD of Ammonia  Urea Plant : 4000 MTPD of Urea

The following paragraphs briefly describe processes involved in such plants, in addition to identification of ancillary facilities necessary for their functioning.

IEFCL has engaged Technology licensors / EPC Contractors for undertaking front end engineering design (FEED) & getting firm bids employing state of the art technology, optimum energy consumption & most environment friendly process.

Both Technology licensors are renowned in the industry and follow the latest process of operation and recovery philosophies.

For the purpose of Environmental Impact Assessment, highest levels of emission and discharge have been taken into account.

About the lifespan of the Project, it is remarkable that:  The Project design shall be suitable for 30 years of operation with planned turn around for maintenance every 2 years or longer.  Design capacity is considered for on stream days of 330 days/ year.  Design and selection of equipment will be to enable operation of the entire complex on a sustained basis for first 24 months, without requiring any turnaround maintenance.

The general process of the two process plants, along with typical material flow diagram of the process are described below.

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3.3.1 Ammonia Plant: The plant is designed to produce 2300 metric tons per day of Ammonia. The Product Ammonia is delivered to Urea Plant. The plant can also deliver the liquid Ammonia to atmospheric storage tank when the Urea Plant is under shutdown.

Methane and heavier hydrocarbons in the feedstock Natural gas & atmospheric air is first reformed using a catalytic process to Hydrogen, Carbon Monoxide, Carbon Dioxide and Nitrogen. The carbon monoxide is further catalytically shifted to carbon dioxide and hydrogen. The carbon dioxide is selectively adsorbed and sent to Urea plant. The balance gas consisting of Hydrogen and Nitrogen (called syn gas) is catalytically synthesized to Ammonia.

Ammonia Plant is designed as per state of art Purifier technology developed by KBR (Kellogg Brown & Roots) with minimum emissions and discharges, having well-defined F&G (Fire and gas) detection system.

All relief valves and pressure control devices are designed for worst cases and connected to dedicated flare. Plant is designed with minimum fugitive emissions having seamless piping and special material selection wherever required. Details of fugitive emissions is mentioned in clause 3.3.5.4 Air emissions detail is mentioned in clause 3.3.5.1 The main input and products of the plant are shown in Figure 3.1. Hereinafter is reported the description of the process shown also in Figure 3.2.

Process flow The Ammonia Plant is a single train plant consisting of: A. Feed and fuel gas supply B. Feed gas desulfurization C. Primary reforming D. Process Air compression E. Secondary reforming F. CO shift conversion, HTS and LTS (High and Low Temperature Shift conversion)

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G. CO2 removal H. Methanation I. Syngas drying J. Cryogenic Purification K. Synthesis gas compression L. Ammonia synthesis M. Ammonia refrigeration system N. Loop Purge Ammonia Recovery O. Hydrogen and Argon recovery P. Process condensate stripping All process operation activities will be run in continuous, exception made for maintenance period of the plant.

Overall block flow diagram of the Ammonia plant and process flow scheme are illustrated below:

Process Air CO2 to Urea

Natural Gas Primary Secondary Shift & CO2 Methanation Reformer Reformer Removal & Dryers

Process Steam

Purge Gas Secondary Fuel to Reformer Purifier

Make up Gas

Cold Ammonia to Storage Ammonia Ammonia Compression Warm Ammonia to Urea Product Synthesis

The material flow block diagram of Ammonia Plant presented above shows main inputs and products only. Pl. refer section 3.3.4 and 3.3.5 for further details on material inputs/outputs expected during the operation phase.

Steam generated in Ammonia Plant is consumed internally in process as well as to drive steam turbines as a prime mover for compressors used in the plant.

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Process Description A. Feed and Fuel The plant feed is natural gas (NG) which will be available at plant battery limit at around 48 kg/cm2g & temperature ~15 deg C. The fuel gas for the reforming & steam boiler is part of the total natural gas delivered at the battery limit. The natural gas fuel for reforming is supplemented by waste gas from Ammonia Plant.

B. Feed gas desulfurization Feed gas supplied at the battery limit passes through slug catcher to separate liquids entrained in the natural gas. The feed gas is then added with a small amount of hydrogen (syn-gas) and heated in the convection area of reforming section. The gas then passes through a bed of cobalt-molybdenum catalyst, which converts organic sulfur into Hydrogen Sulfide (H2S).

In the second step, the H2S is removed in a zinc oxide bed operating in series with lead- lag combination. The desulfurized gas leaving the zinc-oxide bed contains less than 0.1 ppm of sulfur.

C. Primary Reforming The gas leaving the zinc oxide bed is mixed with medium pressure steam to maintain specific steam-to-carbon molar ratio. It is then heated in the convection zone of primary reformer before entering to the reformer catalyst tubes where the gas and steam react in the presence of nickel base catalyst to form hydrogen and carbon oxides.

D. Process Air compression The process air compressor provides air for the secondary reformer. The process air from the final stage of compressor is heated in the convection zone of the primary reformer and then added to the process gas into the secondary reformer.

E. Secondary reforming The gas mixture passes through a nickel based catalyst where the residual methane is reformed to Hydrogen and carbon oxides using the heat generated by the combustion. The process gas leaving the reforming section at about 890 to 900°C is cooled to about

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360°C in the Waste heat boiler, where saturated steam is produced. After cooling, the gas flows to the High Temperature CO-converter (HT CO converter). Saturated steam at 126 kg/cm2 (g) is superheated to 510°C in the super heater coils of the waste heat section of the primary reformer. After superheating, the steam is used in the high pressure steam turbine that drives the air and other compressors.

F. CO shift conversion (HTS and LTS) The carbon monoxide leaving the secondary effluent is further oxidized with water to produce carbon dioxide and hydrogen. This conversion is accomplished in two steps conversion - The High Temperature Shift conversion (HTS) followed by Low Temperature Shift (LTS) converter. Here the CO content is further reduced down to less than 0.30 % vol. (dry).

G. Carbon dioxide removal LP flash

The CO2 removal is performed through two-stage with aMDEA removal system licensed by BASF. The regenerated CO2 is sent to the Urea Plant.

H. Methanation

The gas leaving the CO2 removal section is heated & fed through Methanator catalyst beds where the remaining carbon oxides are transformed into methane and water. Practically the opposite reaction of reforming is used for eliminating carbon oxides from the gas stream going to the synthesis loop as carbon oxides that are harmful to synthesis catalyst. The syngas leaving the Methanator contains less than 5 ppmv of carbon oxides (as CO +

CO2).

I. Syngas drying: The Methanator effluent gas is cooled & the chilled gas flows to the Molecular Sieve Driers. The driers contain solid desiccant. Each drier is sized to remove water, Ammonia, and carbon dioxide to less than 1ppmv.

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J. Cryogenic purification: Dried synthesis gas from the Molecular Sieve Drier flows to the Purifier Expander, which is a turbo expander. Here work energy is removed to develop the net refrigeration required for the Purifier. The removed energy is recovered as electricity in Purifier Expander Generator. The expander effluent is further cooled and partially condensed in Purifier Feed / Effluent Exchanger .The process stream then enters the Purifier Rectifier, which is a trayed column. In the rectifier, the molar ratio between hydrogen-to-nitrogen as needed for Ammonia synthesis is achieved. The condensed excess nitrogen contains all of the methane and about 60% of the argon.

K. Synthesis gas compression: The purified synthesis gas having the correct molar ratio is compressed to the synthesis loop pressure in the Synthesis gas Compressor, which is a two-casing centrifugal compressor. Compressor is driven by Steam Turbine that uses HP steam produced in the Ammonia Plant.

L. Ammonia synthesis: The synthesis loop consists of the 4 bed Horizontal Ammonia Converter, Feed / Effluent Exchanger, Ammonia Converter Effluent/Steam Generator, Ammonia Converter Effluent Cooler, Ammonia Unitized Chiller, Ammonia Separator. The syngas leaving the compressor is first heated up with the converter effluent and then enters to the syngas converter. Ammonia is produced in the three-bed converter, where the hydrogen and nitrogen react over an iron-based catalyst. The reaction is exothermic and heat is recovered into steam generator located in Synthesis loop to generate HP steam.

M. Ammonia gas condensation and Refrigeration: The refrigeration system provides the following: - Cooling of converter effluent in unitized chiller for condensation of Ammonia. - Production of cold (-33 oC) liquid Ammonia product. - Production of warm (38 oC) liquid Ammonia product (normal).

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- Cooling of the makeup synthesis gas in Methanator Effluent Chiller. - Condensation of recovered Ammonia vapor from Ammonia Distillation Column. - Condensation of Ammonia vapor from Ammonia Storage.

Ammonia Refrigeration Compressor is a four casing centrifugal compressor driven by a Steam Turbine. The compressed Ammonia is condensed in Refrigerant Condenser, and flows to the Refrigerant Receiver. From here, it can be exported as warm Ammonia product by the Warm Ammonia Product Pumps. The warm Ammonia product is routed to the Urea Plant. A small slipstream is used as reflux in the Ammonia recovery system. The cold liquid Ammonia goes to Ammonia storage tank when the Urea Plant is under shutdown.

N. Loop purge Ammonia recovery: As described above, the loop purge gas is sent to the HP Ammonia Scrubber, which has two beds of packing, the purge gases are scrubbed with water to recover Ammonia as aqua-Ammonia solution. Similarly flash and inert gases are combined and washed off Ammonia in LP scrubber, the outlet aqua-Ammonia solution is combined and flows to distillation column where NH3 get separated & rectified and flows to Ammonia condenser. Overhead gas from HP scrubber which is almost NH3 free is sent back to process and from LP scrubber to Primary reformer furnace.

O. Hydrogen and Argon Recovery: Hydrogen is recovered in Purge Recovery Plant. After Hydrogen Recovery, residual gas, being tagged as Tail gas, is sent to Argon Recovery Plant where Argon is recovered. After Argon recovery, the recovered gas is recycled back.

P. Process condensate stripping:

The process condensate contains dissolved NH3, Methanol, CO2 which will be removed by steam in Process Condensate Stripper. The overhead steam along with NH3,

Methanol, CO2 is sent back to primary reformer and stripped process condensate sent to Polisher for further treatment.

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105 TPH to Urea plant

78572 Nm3/h (Feed + Fuel)

95.8 TPH to Urea plant 750 m3/h

128100 Nm3/h

122.80 TPH to Urea Plant

8000 KWH

Product Quality: The product Ammonia has the following characteristics at Ammonia Plant battery limit:  Ammonia: 99.90 wt % (min)  Water: 0.10 wt % (max)  Oil: 5 ppm (max)

3.3.2 Urea Plant The Urea Plant is designed to produce 4000 metric tons per day of Urea. Urea plant include two distinct sections: 1. Urea Synthesis section where Ammonia & Carbon dioxide react to produce Urea solution employing the state of the art ACES 21 technology licensed by Toyo Engineering of Japan. 2. Conversion of Urea solution to granules at the Granulator section employing spout bed fluid granulation technology employed by Toyo Engineering of Japan.

The Urea granules produced are sent to storage either for bagging or bulk shipment. Hereinafter is reported the description of the process shown also in Figure 3.3.

The block flow diagram illustrating the material flow is illustrated below:

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Carbamate HP Recovery LP Recovery Condenser

HP LP Ammonia Reactor Stripper Decomposer Decomposer

Process CO2 Condensate Treatment UF85

To Product Handling Granular Vacuum Screening Granulator Urea Concentrator

Recycle

It may be noted that in order to have the highest levels of process safety, all relief valves and pressure control devices are designed for worst cases and connected to dedicated flare. Plant is designed with minimum fugitive emissions and special material selection have been employed wherever required. Details of fugitive emissions is mentioned in clause 3.3.5.4 Air emissions detail is mentioned in clause 3.3.5.2

Urea Process flow Urea process is characterized by the following main process steps:

A. Urea synthesis, NH3 & CO2 recovery section at higher pressure

B. Urea purification along with NH3, CO2 recovery at two lower pressures C. Urea concentration D. Process Condensate treatment E. Granulation.

Brief description of each of each of the sections is given below.

A. Urea synthesis , NH3, CO2 recovery at high pressure Urea is produced through synthesis of Ammonia and carbon dioxide. The Ammonia and carbon dioxide react to form ammonium carbamate, a portion of which dehydrates to Urea and water.

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The fraction of ammonium carbamate that dehydrates is determined by the ratios of various reagents, the operating temperature, pressure and the residence time in the Reactor. The reaction products leaving the reactor flow to a stripper, a vertical in tube falling film decomposer in which the liquid, distributed on the heating surface as a film, flows by gravity to the bottom. As the liquid film flows, it gets heated and decomposition of carbamate through surface evaporation takes place. Generated Vapours (essentially Ammonia and carbon dioxide) are removed by flowing to the top of the stripper. This gaseous stream with the recovered solution from the downstream sections is condensed and recycled to the Urea reactor by means of carbamate ejector.

B. Urea purification and NH3, CO2 recovery at two lower pressures Urea purification and overhead vapors recovery take place in two stages at decreasing pressures. The exchangers where Urea purification occurs are called decomposers. In these equipment, the residual carbamate decomposition takes place. The decomposed carbamate vapors are condensed and recycled back to the synthesis loop while the inerts are washed in the washing column before being sent to the flare stack. The Urea solution exiting this section is purified to generate Urea solution of 69-71 wt %.

C. Urea concentration section In order to granulate Urea, concentrated Urea solution of 97 wt% is necessary. This is achieved in vacuum concentration stage. The Urea solution leaving the purification sections having about 70% wt Urea, along with the Urea solution recycle coming from granulation unit, is sent to the Urea concentration section. The concentration happens in vacuum conditions employing vacuum generation system. The concentrated Urea solution (∼97 % by wt.), is sent to granulation unit, after mixing with UF85 additive (Urea Formaldehyde Concentrate) as anti-caking agent.

D. Process condensate treatment

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The process condensates containing NH3, CO2 and Urea coming out from vacuum system is treated in this section to ensure that the condensate have an almost free-of- contaminants. The treated process condensate is further sent to the Polisher unit. The NH3 & CO2 separated from the process condensate stripper are mixed with the Low Pressure Decomposer overhead vapors, condensed and further recycled back to the synthesis loop.

E. Granulation The Urea solution is fed on the Urea seeds in the granulator bed through the multi spray nozzles to enlarge the recycle particles (seeds) through agglomeration of the solution to seeds. The water in the feed Urea solution is evaporated in the granulator. The enlarged granules are cooled to a suitable temperature by fluidizing air on the internal fluidized beds in the granulator. Urea granules produced in the granulator are screened to separate the product size granules from over and under size granules through the double deck screen. Small sized granules are recycled back to the granulator as the seed and oversized granules are crushed through the double roller type crusher and recycled back to the granulator together with the under sized granules as the seeds. Exhaust air from the granulator and cooler is scrubbed in the wet type dust scrubber to recover the Urea dusts in the exhaust air. The water used in the dust scrubber to dissolve the urea dust is recycled back to the Urea plant to recover the Urea by evaporating the water.

AMMONIA - 93.612 TPH

UREA PRODUCT- 166.67 TPH CARBON DIOXIDE - 121.876 TPH UREA PLANT

POWER - 71.5 KWh/T OF UREA

Figure 3.3: Material flow Block diagram of proposed Urea plant

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3.3.3 Utilities Description 3.3.3.1 Power generation Power will be provided by the existing captive power plant in IEPL complex. The power plant consists of five General Electric model MS-6001 gas turbine generators which are rated at 11500 volts, 3 phase and 50 hertz. Each generator supplies power to 33 kV switch board at the main substation through the step up transformers. Power for fertilizer project is tapped off from the 33 KV bus in main substation. Each of the gas turbines can produce approximately 33 MWH of power. While the existing power consumption is about 82 MW, the new facilities are expected to consume an additional 30 MW. Thus the installed capacity is more than sufficient to meet the power demand of IEFCL-Train2 project as well.

In addition to the above, IEPL manufacturing complex is equipped with four nos. of emergency diesel generators (EDGs) manufactured by Mitsubishi heavy industries to supply emergency power in the event of outages of gas turbines. The complex has 12 MW of emergency power capacity.

3.3.3.2 Raw Water Treatment Two new borehole pumps, filter water package & DM plant will be installed as part of the IEFCL-Train2 project. Bore holes are the only source of raw water for Train-2 fertilizer project. During normal operation, the total requirement of water will be approximately 750 m3/hr. For meeting this requirement, two (2) new boreholes will be drilled.

The raw water from the bore holes will be treated through de-carbonator. The decarbonated (to remove carbon dioxide) water will be used for firefighting. The decarbonated water is further treated through filtration devices (to remove suspended solids) and used for cooling tower make up, plant water and also as feed to DM plant.

3.3.3.3 Demineralized Water & Condensate Polishing System A. Demineralized Water System

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IEFCL-Train2 shall be equipped with a new DM plant to generate the demineralized water make-up for steam generation. DM Plant is having cation, anion & mixed bed exchanger to produce ultra-pure water. The demineralized water is further de-aerated to produce Boiler Feed Water (BFW) suitable for High pressure steam generation in the various boilers in Ammonia plant. Generated steam is used in reforming process as well as motive fluid for steam turbines to drive the various compressors in Ammonia & Urea plants.

B. Condensate Polishing System A New Condensate Polishing System will mainly treat process condensates from Ammonia & Urea Plants & Steam Turbine condensates. Condensates are first passed through Cartridge Filters. After microfiltration, condensates are treated in the Mixed Bed Polishing System to be reused as demineralized water, after reducing salts & silica contents to desired levels to be acceptable for production of steam in boilers.

To regenerate cation & anions resins, sulphuric acid and caustic soda are used respectively.

3.3.3.4 Steam Generation and Boiler Feed Water System Steam Generation: IEFCL Train 2 project shall also install new steam generation and boiler feed water facilities. The steam generation systems consist of dedicated auxiliary boiler (where Natural Gas is used as fuel) as well as waste heat boilers to recover the process heat generated during the reforming as well as synthesis of ammonia. It may be noted that the net steam production in the complex is quite low at about 50 MT/Hour during normal operation through the efficient process employed to recover the heat energy.

The high pressure steam is mainly used to drive turbines driving the compressors in Ammonia & Urea units as well as in the reforming & CO shift processes.

A. Auxiliary Boiler

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The Auxiliary Boiler Package is provided in order to supply steam during plant start-up as well as for steam demands of Urea process. During normal complex operation the Auxiliary Boiler run at about 40 % of load while the maximum capacity has been evaluated considering the expected steam consumption during the transient scenarios (such as Ammonia secondary reformer Start-up).

Auxiliary Boiler is designed according to the following main characteristics: - Steam capacity (MCR) = 125 t/hr maximum - Steam pressure at outlet = 47.4 kgf/cm2(g); - Steam temperature at outlet = 404°C - Fuel supply = Natural gas

B. Boiler Feed Water (BFW) A boiler feed water de-aerator capable to serve all the BFW users of the Ammonia & Urea plants has been considered. It has been designed to provide de-aerated boiler feed water at 110°C having characteristics to produce steam with a quality in agreement with ASME guidelines. The de-aerator will have a hold-up capacity of 15 minutes (at design flow rate) before the low level switch stops BFW Pumps.

3.3.3.5 Cooling Tower New cooling towers of sufficient capacity shall be installed to supply cooling water for Ammonia, Urea and Utilities plant users. To cover water losses due to evaporation, drifting and blow down, the cooling water basin is equipped with level measurement to control the flow rate of make-up water. Make-up cooling water shall be supplied from the water treatment plant.

Since there is provision for maximum reuse of boilers blow down as cooling water make- up, the selection of cooling water treatment will take into account adequate chemical dosing equipment to avoid any algae proliferation.

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A continuous blow-down flow rate is provided in order to keep under control the dissolved solid particles within the water circulation system in both Ammonia & Urea distribution. Concentration cycles have been designed as 6.

3.3.3.6. Effluents treatment system Liquid wastes are generated from the boiler blow downs, air compressor intercoolers, turbine condensates, steam condensates, process condensate, and oily effluent from the various processing units. Some waste streams will be individually treated in the Ammonia and Urea plant before being channeled into condensate polisher unit for reprocessing and reuse as boiler feed water. Some other streams shall be sent to the ISBL waste water treatment system. A description regarding the treatment approach of various effluent streams is given below:

A. Boiler Blow Down Boiler blow down will be routed to the cooling tower basin as make-up.

B. Condensate from Air Compressor Intercoolers Condensate from Air Compressor Intercoolers will be routed to the cooling tower basin as Make-up.

C. Turbine Condensate Turbine condensate will be sent to the polishing unit and shall be reused as BFW (boiler feed water) after polishing. In case the turbine condensate is off spec, it will be transferred to the ISBL effluent treatment section.

D. Steam Condensate Steam condensate will be sent to the polishing unit and reused as BFW after polishing. In case the steam condensate is off-spec, the same shall be transferred to the ISBL effluent treatment section.

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E. Process Condensates Process condensate generated in Ammonia Plant is treated in dedicated stripper and the treated condensate is sent to the polishing unit and reused as BFW after polishing. In case the process condensate is off-spec, the same shall be stored in a tank in Ammonia plant and gradually treated in the medium pressure process condensate stripper. Provision is also provided for diversion to ISBL effluent treatment section.

Process condensate generated in Urea Plant is treated in dedicated hydrolyser and stripper and the treated condensate is sent to the polishing unit and reused as BFW after polishing. In case the process condensate is off-spec, the same shall be stored in a tank in Urea plant and gradually treated in the hydrolyser and stripper. Provision is also provided for diversion to ISBL effluent treatment section.

F. Oily Water Oil contaminated water is collected in a spill wall or into an oil trap of a pit for each potential source of oily water. Oil is skimmed manually at each pit periodically and further removed in oily water separator such as CPI separator prior to discharging to the ISBL treated effluent pit.

G. Chemical Drain Chemical Drain around the boiler is collected and sent to the existing neutralization pit. Chemical Drain from the amine area is collected to the aMDEA solution sump and recovered in aMDEA Storage Tank.

H. Floor Washing Water in Urea Synthesis Area In Synthesis area, the spilled process fluid on the surface of the paving or equipment is washed by steam condensate and collected in dedicated pits inside Urea plant. The collected water is treated in hydrolyser and stripper and the treated stream is sent to the ISBL treated effluent pit.

I. Floor Washing Water of Granulation Area

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Granulation area is designed in such a way that wash water containing Urea is collected in Dissolving Pit and recovered to Urea Plant. The spilled process fluid on the surface of the paving or equipment is washed by steam condensate and sent to Dissolving Pit. There is no discharge to waste water system from granulation area.

3.3.3.6.1: Inside plant battery limit effluent treatment The water consumption is optimized itself in technology and design of plants. Boiler blow down and condensate from air compressor intercooler is routed to cooling tower make-up. The granulator wash water is routed to dissolving tank for recovery. Chemical Drain from the amine area is collected to the aMDEA solution sump and recovered in aMDEA Storage Tank.

The process condensates generating in ammonia and urea plant are being treated inside plants and treated process condensates is being routed to condensate storage tank. The steam and turbine condensates also routed to this condensate storage tank. The homogenized and mixed condensate is treated in polisher unit to remove salts and silica. The purified water is used as boiler feed water.

The floor washing water from urea synthesis section is collected in dedicate pits inside urea plant and treated in hydrolyser and stripper. The treated stream is routed to treated effluent pit. The scheduled quality control on treated stream is administered to access the performance of treatment facility.

The re-generation effluent generated during regeneration of polisher resin is collected in dedicated neutralization pit having neutralization facility and after pH correction, transferred to ISBL treated effluent pit.

The treated effluent pit have neutralization facility for pH correction The air sparer are also provided to improve the water quality by increasing dissolved oxygen concentration. The treated effluent from treated effluent pit is routed to equalization pond by means of closed pipe line. The control valve installed at up-stream of discharge pump is

Chapter Three: Project Description 3-20 IEFCL -Train2 Fertilizer Project EIA Report controlled by DCS and operating logic is configured with pH of discharged treated effluent. If the pH of treated effluent goes beyond 8.0 or less than 6.5, then the control valve automatically closed and stop the transfer to equalization pond. In such cases the pump discharge recycled back to treated effluent pit by recycle line. The diagram showing the ISBL effluent treatment and re-use facility is illustrated below:

Ammonia Process Polish water

Stripper line condensate used as BFW - To Equalization Pond

Turnine Condensate

pH monitoringpH Quality controlQuality on and checks Polisher Condensate Unit (03 Storage Tank Nos.) ISBL Treated effluent Pit Steam Condensate

Urea Process Hydrolyer and Neutralization pit for condensate Stripper regeneration effluent After pH correction

On-line monitoring facility at DCS; Scheduled quality control checks is in place Floor washing of Hydrolyer and Urea synthesis area Stripper

Oily water from After Oil removal, oil free water CPI Seperator for Oil Plants

3.3.3.6.3: Final treated effluent Final treated effluent in ISBL effluent treatment facility, is directed to the equalization pond for dilution and neutralization if required before sending to holding ponds. The total holding capacity of the two holding ponds amount to 40,000M3. After checking the quality of effluent at holding pond outlet, it will be discharged to the retention pond, in controlled manner. In the retention pond, it is further mixed with storm-water runoffs from the premises and discharged to Oluka River. It may be noted that the discharges from the Retention Pond is carried out only when the pond is full & not discharged daily.

Total effluent generated by Train-2 fertilizer plant will only be 20 -25 M3/hr. however another 100 M3/hr. water from cooling tower blow down and DM plant will be sent directly to equalization pond.

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The existing facilities i.e. equalization basins and holding ponds have sufficient capacity capable to manage the effluent generated by new IEFCL –Train2.

Sanitary waste from fertilizer plant which will be about 4-6 M3/hr and will be treated in existing facilities. Existing facility is having spare capacity of about 25 M3/hr.

3.3.3.7: Nitrogen System Existing petrochemical complex is having two nos. of air separation units, generating gaseous nitrogen & liquid nitrogen. Gaseous nitrogen is directly supplied to process plants while liquid nitrogen is stored in liquid storage tanks for emergencies. A new air separation unit is being added to augment the existing capacity and meet the requirement of IEFCL-Train2.

3.3.3.8: Natural Gas System The system will be designed to supply continuously: • Natural gas feedstock to Ammonia Plant • Fuel gas to Primary Reformers (Ammonia Plant) • Fuel gas to Auxiliary Boiler. • Fuel gas (assist gas/purging gas) to flares

3.3.3.9: Ammonia Storage Tank IEFCL-Train1 is equipped with one Ammonia storage tank having the following characteristics: • Capacity: 15000 metric tons of liquid Ammonia • Internal Diameter: 33000 mm • Height: 27000 mm • Operating pressure (min/max): 200/400 mm H2O(g) • Temperature: -33 °C • Max. Daily Boil-off: 0.04% by wt. of full storage capacity One new Ammonia Storage Tank of similar specification is proposed for IEFCL – Train2

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The Ammonia storage tank will be double wall – double containment type, designed and constructed so that both the primary and secondary self-supporting containers shall be capable of independently containing the stored liquid.

Both inner & outer tank walls and bottoms will be made of low temperature materials and designed for product deriving loads. The secondary containment structure will be independent from that of the primary tank. Thermal insulation of inner shell, roof and bottom will be such as the maximum allowed boil-off does not exceed 0.04% of capacity per day.

The boil-off ammonia vapour is routed to refrigeration compressor of Ammonia plant to recycle back in main ammonia stream. In shut down condition of Ammonia plant, the boil-off ammonia vapour is compressed by BOG compressor and recycle back to the storage tank. A dedicated flare stack adequate for complete burning of ammonia vapours, released during any emergency situation, is provided. The continuous pilot flame at flare tip maintained to ensure complete burning of ammonia vapours assuring that unburnt ammonia will not release in atmosphere in any case.

Ammonia storage tank will be equipped and provided with the necessary instrumentation capable of monitoring and controlling both normal operation and emergency occurrences, while assuring the highest reliability and operability. Ammonia Storage Tank will be provided with pressure relief valves and with vacuum relief valves adequate to manage any emergency.

3.3.3.10: Urea Storage After the Urea has been produced, it must be stored for shipment. From the granulator, the Urea will be transported by belt conveyor to the storage building. The new storage area will be capable of holding 60,000 metric tons of Urea. Storage building will be equipped with air conditioning facility to avoid lump formation of the product. Portal scraper reclaimer will be used to reclaim the product onto a belt conveyor for export to Bulk truck loading system.

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3.3.3.11: Fertilizer plant system control Distributed Control System, DCS, the most modern Control Platform is used for the Fertilizer Plant Control System. DCS centralizes plant operations to provide flexibility and simplicity by allowing central control, monitoring and reporting of individual components and processes. The redundancy within DCS facilitates high system availability and reliability. The DCS Controllers and associated inputs / outputs are connected through integrated redundant communications network to operating and engineering stations. The stations have graphical displays, easy-to-use displays for data monitoring, data logging, alarming and control. Field devices are directly connected to input / output modules that communicate with assigned controllers while reading and reporting real parameters.

DCS, ESD & FGS systems will be connected on an integrated redundant control network, Vnet/IP, that is used as real time control network connecting all active DCS, ESD & FGS components. Emergency Shut-Down System, ESD, or the safe-guarding system, shall automatically bring the relevant equipment or part of the plant to a safe condition, when a critical process variable reaches the limit of an acceptable value.

3.3.3.12: Non-Plant Facilities All IEPL’s existing Non-plant facilities such as a fire station, medical center, canteen, warehouse, garage/vehicle repair shop, etc. will be used and augmented if necessary.

3.3.4 Utilities for Construction Raw materials (Including Utilities for construction) Input and Product/Material Output The main materials to be used during construction phase will be:  Construction materials (cement, bricks, steel, plastic pipe, wood),  Electric power,  Construction water  Compressed air,

Total water and energy consumption, during construction amount to:

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 Water: Total consumption will be approximately 230,000 m3.  Diesel consumption (only for construction equipment): Total consumption will be approximately of 7,000 KL, average consumption around 280 KL/month from month 4, peak during the months 14-29 of 320 KL/month.

Source of water and power for construction will be from existing facilities It is essential to give an assessment of materials input and output in terms of loads and volumes during operation. The information presented below was supplied by the technology licensors of the project:

Table 3.2: Consumption of raw materials and product output for a typical Ammonia Plant Source Ammonia – 2300 MTPD Destination Input Output Gas supply Co. Natural Gas 64,575 NH3 95,833 To Urea 3 Feed Nm /h CO2 kg/h plant/Ammonia 122,800 storage Kg/hr Gas supply Co. Natural Gas 13,240 - - - 3 Fuel Nm /h Gas supply Co. Natural Gas 2775 - - - Fuel for Boiler Nm3/h From existing Nitrogen 220 Nm3/h - - - facility Plant air header Compressed 200Nm3/h Compressed 5,418 For instrument air air from Nm3/h & plant air process air header compressor From Instrument 450 Nm3/h Turbine 113600 To condensate instrument air Air condensates kg/h storage tank dryer Condensate DM Water 386,500 Low Pressure 1,653 kg/h To SLL header polishing/ kg/h steam from DM Plant boiler BD DM Plant DM Water 30,000 kg/h ------Medium 104,500 To Urea Plant pressure kg/h Steam export

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Ambient Air to process 127,962 Stripped 91,500 Condensate air Nm3/h process kg/h polishing unit compressor condensates

Cooling tower Circulating 209,800 - - - cooling water m3/h

Existing Power Electric Power 10,919 kWh - - - Plant

Notes: CT – Cooling tower, BD- Blow down Herein the pressure related to High, Medium, Low pressure indicated in Table 3.1:  High pressure steam : 126 Kg/cm2(g)  Medium pressure steam : 46.5 Kg/cm2(g)  Low pressure steam : 3.5 Kg/cm2(g)

Table 3.3: Consumption of raw materials & product output for a typical Urea unit process Urea – 4000 MTPD Source Destination Input Output Ammonia NH3 93,745 kg/h Urea granules 166,667 Bagging plant/ Plant/ kg/h Bulk Silo Storage tanks Ammonia CO2 121,859 kg/h - - - Plant - - - Water Vapor to 288 m3/h - atm from Urea Cooling Tower

UFC tank UFC 1,250 kg/h CO2 compressor Atmosphere to atm:  Inerts 50 Nm3/h

 CO2 605 kg/h Cooling Circulating 16,500 m3/h - - - tower cooling water Atmosphere Atmospheric 1,431,886 Saturated air to Atmosphere air Kg/hr Atm. 34 kg/h  NH3 34 kg/h  Urea dust 1,431,886 Dry air kg/h

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Existing Electric 9,426 kWh Power Plant Power

3.3.5. Types and sources of air emissions 3.3.5.1 Sources of Gaseous Emissions for the Ammonia Plant The Plant is designed to minimize emission and effluents during normal and startup operations. Design features are described hereunder.

Process Heater (Primary Reformer) In Primary reformer, purge gas and flash gas are burned with natural gas to supply the energy for the reforming reaction. Purge gas and flash gas contain Ammonia which is an emission source of nitrogen oxides. In order to reduce nitrogen oxides discharged from the Primary Reformer stack, the following countermeasures are taken: 1) Fuel Gas from Recovery Unit The Ammonia in the purge gas and the flash gas is completely recovered in Ammonia Recovery Unit and the treated gas is used as fuel gas, which is sufficient to restrict nitrogen oxide emission from the Primary Reformer. 2) Besides, the gas burners selected are of Low NOx Burners

Package Boiler In package boiler, natural gas is used as fuel. The use of low sulphur containing clean fuel is reducing the sulphur dioxide contain in flue gas. The NOx emissions are reduced by selecting advanced designed low NOx Burners.

Stripped Vapor from Condensate Stripper: Process Condensate contains some impurities such as Ammonia, carbon dioxide and methanol. These impurities are stripped with steam in the condensate stripper to reuse the condensate as boiler feed water. This application is useful for elimination of emission source. The stripped vapor containing impurities is delivered along with medium pressure steam to the Primary Reformer tubes, in which impurities are decomposed on reformer catalyst. Therefore, there is no emission from Condensate stripper.

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Stack and Venting System: Flare stack and process vents can also be source of emission in plant during upset situation. Each flare stack is designed for complete burning of hydrocarbons even at the highest discharges in upset condition. Stack and vent system emissions are not continuous but all the same considered under emission limits for specific pollutant from stationary sources and regulated by Guidelines and Standards for environmental pollution control in Nigeria (FMENV 1991). 3.3.5.2 Sources of Gaseous Emissions for the Urea Plant 3.3.5.2.1 Emission control in Urea Plant Major emissions from the Urea Plant are Ammonia and Urea. These emissions are caught and recycled back to process in an efficient manner, reducing emissions of pollutants to the atmosphere and drainages. This creates additional merit of raw material consumption (Ammonia) per ton of Urea product. The Fig 3.4 below explains the inbuilt emission control system in the Urea plant to ensure 100% recycling of raw materials/products that would have ended up as emission.

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Figure 3.4 Emission control system for fertilizer plant All drains from Urea Plant which contain Urea and Ammonia are collected into closed collection system and the solution is recycled to Urea Plant to capture even the spill on plant floor.

Stripped Vapor from Condensate Hydrolyser and Stripper: Process Condensate contains some impurities of Urea, Ammonia and carbon dioxide. Process condensate first treated in Urea hydrolyzer, where urea is hydrolyzed in to ammonia and carbon dioxide. Thus formed, ammonia and carbon dioxide, together

Chapter Three: Project Description 3-29 IEFCL -Train2 Fertilizer Project EIA Report with those in the process condensate, are stripped out by steam stripping. The overhead stripped gaseous mixture (Ammonia, carbon dioxide and water vapor) from process condensate stripper is recycled to LP Decomposer and recycled back to the main process stream. The treated process condensate is recycled as boiler feed water after treatment in polishing units. Therefore, there is no emission from Condensate hydrolyzer and stripper.

Exhaust Air from Granulation Urea dust and Ammonia contained in the exhaust air from the granulator can be a source of air pollution in Urea plant. A unique dust recovery system proven in many commercial plants has been incorporated to reduce the Urea dust and Ammonia content in the exhaust to less than 50 mg/Nm3-air.

3.3.5.3 Air emissions and applicable standards The applicable emissions limits for the new IEFCL Train-2 Project will be in compliance with the International standards, as IFC, Ed. April 30th, 2007 Environmental, Health and Safety Guidelines-Nitrogenous Fertilizers; requirements for specific pollutants release from Nitrogenous Fertilizer Plant (Ammonia - Urea). IFC limits - Ed. December 19th, 2008, Environmental, Health and Safety Guidelines-Thermal Power Plants (> 50MWth) and Ed. April 30th, 2007, Environmental, Health and Safety Guidelines-General EHS Guidelines: Environment “Air Emissions and Ambient Air Quality” (3 MWth ÷ 50 MWth) - are applicable to the gaseous emission released from the boilers, while for other pollutants (SOx, CO; HC, VOC), that are not normed, the Nigerian legislation (FMENV, 1991) is used. However, the more stringent limits are applicable. In the following paragraphs, the emission source characteristics are reported in compliance with the applicable legislation and standards.

Primary Reformer  Ref. 1 - IFC, Ed. April 30th, 2007 – Nitrogenous Fertilizers – Table 1 – Ammonia Plant;  Ref. 2 - FMENV, 1991 - Interim Guidelines and Standards for Industrial Effluent, Gaseous Emissions and Noise Limitations, Table 3.2 - Emission Limits for Particulates from Stationary Sources (Furnaces) & Table 3.3 - Emission Limits for Specific

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Pollutants from Stationary Sources.

Table 3.5: Emission characteristics of the fertilizer plant (Primary reformer)

Pollutant Unit Limits acc. to REF. 1 Limits acc. to Emissions REF. 2 expected

NOx mg/Nm3 300(*) 350-1000 <150 SO2 mg/Nm3 NN 30-3000 <2.0 TSP/PM mg/Nm3 50(*) 75-600 <50 Note: (*) Assuming the following conditions, indicated in Table 1 of IFC EHS Guidelines for Nitrogenous Fertilizer production: T=273 K (0 °C), P=101.3 kPa (1 atmosphere), Oxygen content 3%, dry conditions.

Auxiliary Boilers  Ref. 1a - IFC, Ed. December 19th, 2008 – Thermal Power Plants, Table 6 (C);  Ref. 1b - IFC, Ed. April 30th, 2007 – Air Emissions And Ambient Air Quality, Table 1.1- 2;  Ref. 2 - FMENV, 1991 - Interim Guidelines and Standards for Industrial Effluent, Gaseous Emissions and Noise Limitations, Table 3.2 - Emission Limits for Particulates from Stationary Sources & Table 3.3 - Emission Limits for Specific Pollutants from Stationary Sources. Table 3.6: Emission limits for the fertilizer plant (Auxiliary Boilers) adopted (based on IFC and FMENV Guidelines)

Pollutant Unit Limits acc. to Limits acc. to Emissions REF. 1 REF. 2 expected

NOx mg/Nm3 240 NN <150 SO2 mg/Nm3 NN 30-3000 <2.0

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CO mg/Nm3 NN NN Not relevant TSP/PM mg/Nm3 NN 75-600 Not relevant Note: Emissions from the combustion of Natural Gas; T=273 K (0oC), P=101.3 kPa (1 atmosphere), Oxygen content 3%, dry conditions. Boiler with capacity > 50 MWth. NN = Not normed

Granulation Tower  Ref. IFC, Ed. April 30th, 2007 – Nitrogenous Fertilizers – Table 1 - Urea Plant Emission characteristics are shown in the following table:

Table 3.7: Emission characteristics (Granulation Unit) adopted from IFC Guideline

Pollutant Unit Limits acc. To IFC – Urea Emissions Plant expected TSP/PM3 mg/Nm3 50 <50

3 NH3 mg/Nm 50 <50

CO2 Emission stacks The CO2 exhausted emissions from the process plant in the normal operation are shown in the following table 3.8: Table 3.8 Quantity of CO2 exhausted from the process plant Source Quantity ton/hour Quantity ton/year @ 330 days operation Primary Reformer 28.31 224,215.2 GTG Power 20.57 162,914.4 Auxiliary Boiler 5.95 47,124 Flares 0.45 356,4

3 As urea dust.

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3.3.5.4 Fugitive emissions The fugitive emissions are leaks from flange, pump, sealed or tightened equipment. A significant proportion of fugitive emissions are losses from unsealed sources, including storage tanks, open-ended (not blanketed) lines, pressure-relief valves, vents, flares, blow-down systems and spills. In other cases, these losses may be caused by leaks in the sealing elements of particular items of equipment, such as:  Pipes / flanges;  Valves and fitting;  Compressors,  Pumps;  Sampling connection;  Incorrect process conditions. The emissions from the pipes derive essentially from flanges and connections, such as sampling points. The general approach for minimizing fugitive emissions, is thus to minimize the length of pipe runs and to minimize the number of connections. The valves are generally considered the main sources of fugitive emissions in the process industries. Fugitive emissions from the compressors arise generally from seal on compressed gas line and oil seal. Fugitive emissions from a pump arise from seal on liquid line and oil seal. The good approach to minimize fugitive emissions from valves, compressors and pump is the implementation of the preventive maintenance and the leak detection program. Fugitive emissions from sampling connections can be controlled by returning the purged materials to the process, or by sending it to a control device. Table 3.9: The sources and the types of fugitive emissions from the proposed plants

Source Type of release Ammonia Plant

Valves, flanges, seals, sample points NH3, CO2, H2, Natural gas Urea Plant

Valves, flanges, seals, sample points NH3, CO2, Formaldehyde, H2, Natural gas, Dust (from loading system)

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Auxiliary Boilers

Valves, flanges, seals, sample points CO2, H2, Natural gas Utilities

Valves, flanges, seals, sample points CO2, H2, Natural gas

3.3.6 Waste Generated and Estimated Quantities Waste type and estimated quantities during construction phase are shown in table (3.10) below. The duration of construction activities up to mechanical completion is about 32 months. During normal operation, spent catalysts will be sent back to manufacturers and other wastes are not significant and will be handled as per the existent Waste Handling System (chapter 4).

Wastes contributed by these new plants would only add to the existing stream. So the general management will involve utilizing existing plan so that the cumulative effects do not exert negative effect on the environment.

Strict adherence to standard operating procedures during production process and operation of the waste infrastructure (such as incinerators and Water Treatment Plants) will address the reduction of wastes from source.

The 4R principles of reduce, re-use, recycle and recover would help to put to useful items such as empty plastic/metal drums, pipe cutoffs, wood pallets etc.

Table 3.10: Waste types and estimated quantities during construction activity Activity Description Quantity Destination Site preparation / Cement / concrete - concrete 3000-3500 Land fill ton/year debris, soil ton/year Foundations containing cement Scrap metal / wire - strips of metal, 200-500 Resale metal supports, pieces of wire ton/year

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Construction Scrap plastic / PVC 20-30 Recycle activities ton/year Maintenance Paints and solvents - traces of 0.3-0.5 Scrap yard operations paint, solvents, etc. ton/year Light bulbs, fluorescent light 0.2 ton/year Stored in fittings; Equipment which can designated place contain traces of neon and tungsten Personal Used PPE - goggles, gloves, etc… 5 ton/year Incinerator Protective Equipment (PPE) from work activities Lube oil and seal Lube and seal oil - oil containing 1.3-1.8 Resale flushing of weld splatter, ton/year machinery chips, welding flux deposits, skid (Pre- powered metal Commissioning oxides phase) Camps, kitchen, Cooking organic wastes 10-20 Municipal/Approv offices ton/year ed dump side operations Mixed urban wastes 150-200 Municipal/Approv ton/year ed dump side Medical wastes 0.05-0.10 ton Incinerator / year Wastewaters (drinking, washing, 250 lt/day Existing ETP shower, per sanitary) worker

The above waste type and quantities are based on Contractor’s documents. During operation, no solid hazardous waste is generated from Ammonia/ Urea plant. 3.3.6.1 Hazardous Substance The Hazardous materials that may be used in the site include diesel fuel, gasoline (during construction) and aMDEA solution, lube oils, Diesel oil and Urea. The source of gasoline & diesel will be the existing fuel station in IEPL. Urea Formaldehyde-85 (During operations) will be used too. The table below specifies the hazardous nature to the environment:

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Table 3.11: Hazardous materials to be used on site during construction/operations Phase Material Safety properties Impact to environment Quantity Construction Diesel Hazardous/flammable Toxic for groundwater and 5150 fuel aquatic environment ton/month Gasoline Hazardous/flammable Toxic for groundwater and 120 ton/month aquatic environment Operation aMDEA Hazardous/ Toxic for groundwater and 3.0 Kg/hr flammable/slightly aquatic environment toxic Any spillage from tank will be collected and reused. UF-85 Hazardous/flammable/ Toxic for groundwater and 1250 kg/h toxic aquatic environment Sulphuric Hazardous/Toxic Toxic for groundwater and 85 Kg/hr acid aquatic environment

These hazardous materials will be handled as per SOP (Standard operating procedures) under proper supervision and the guidance as per MSDS (Material safety data sheet). Besides that, the proper labelling of containers, display of MSDS and availability of secondary containment, spill control equipments will be ensured. The spill of sulphuric acid will be washed with plenty of water and this water will be routed to effluent treatment facility.

Any spillage of aMDEA and UF-85 is collected and reused. During construction minor spill during transfer of diesel/gasoline will be collected in secondary containment and reused. 3.3.7 Energy Conservation The technology selected is proven with respect to energy consumption and lowest among the technologies available in the world for ammonia and urea production. The specific energy consumption for urea production will be 20.53 MMBTU/MT.

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Besides that, IEFCL will adopt suggestions indicated by IFC Guidelines (Ed. April 30th, 2007 – Energy Conservation) about the Energy conservation approach for process heating, cooling and compressed air system in the project.

The majority of IFC suggestions for energy conservation has been adopted as follows (Table 3.12)

Table 3.12: Measures to provide Energy Conservation taken by IEFCL for Fertilizer plants Sr. No. Measures Taken 1 Adequate insulation to reduce heat losses through furnace/heaters etc. structure 2 Recover heat from hot process or exhaust streams to reduce system loads 3 Use low thermal mass insulation to reduce energy required to heat the system structure to operating temperature, in intermittently‐heated systems 4 Control process temperature and other parameters accurately to avoid, overheating or over-drying 5 Review opportunities to schedule work flow to limit the need for process reheating between stages 6 Operate furnaces/heaters at slight positive pressure, and maintain air seals to reduce air in‐leakage into the heated system 7 Reduce radiant heat losses by sealing structural openings 8 Where possible, use the system for long runs close to or at operating capacity 9 Near net weight and shape heat designs 10 Robust Quality assurance on input material Heat Distribution Systems 1 Avoid steam leaks despite a perceived need to get steam through the turbine 2 Regularly verify correct operation of steam traps in steam systems and ensure that traps are not by‐passed. Provision of steam trap operational philosophy 3 Insulate distribution system vessels, such as hot wells and de‐aerators, in steam systems and thermal fluid or hot water storage tanks 4 Insulate all steam, condensate, hot water and thermal fluid distribution pipework, down to and including 1” (25mm) diameter pipe, in addition to insulating all hot valves and flanges

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5 In steam systems, return condensate to the boiler house for re‐use, since condensate is expensive boiler‐quality water and valuable beyond its heat content alone 6 Use flash steam recovery systems to reduce losses due to evaporation of high‐ pressure condensate 7 Consider steam expansion through a back‐pressure turbine rather than reducing valve stations 8 Eliminate distribution system losses by adopting point‐of-use heating systems Energy Conversion System Efficiency Improvements

1 Consider combustion automation using oxygen‐trim controls 2 Minimize the number of boilers or heaters used to meet loads. Minimize the number of boilers kept at hot ‐ standby 3 Use flue dampers to eliminate ventilation losses from hot boilers held at standby 4 In steam boiler systems, use economizers to recover heat from flue gases to pre‐ heat boiler feed water or combustion air 5 Adopt automatic (continuous) boiler blow down 6 Recover heat from blow down systems through flash steam recovery or feed‐ water preheat 7 Do not supply excessive quantities of steam to the deaerator Process Heating: Measure 1 Fuel quality control/fuel blending Process cooling: Measures Heating Load Reduction 1 Adequate insulation to reduce heat gains through cooling system structure and to below‐ambient temperature refrigerant pipes and vessels 2 Control process temperature accurately to avoid overcooling 3 Operate cooling tunnels at slight positive pressure and maintain air seals to reduce air in‐leakage into the cooled system, thus reducing the energy required to cool this unnecessary air to system operating temperature 4 Pre‐cool using heat recovery to a process stream requiring heating or by using a higher temperature cooling utility 5 In cold and chill stores, minimize heat gains to the cooled space by use of air curtains, entrance vestibules or rapidly opening/closing doors. 6 Energy efficiency techniques, in the case of air conditioning applications:

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 Placing air intakes and air‐conditioning units in cool, shaded locations  Improving building insulation including seals, vents, windows, and doors  Planting trees as thermal shields around buildings  Installing timers and/or thermostats and/or enthalpy‐based control systems.  Installing ventilation heat recovery systems 7 Exploit high cooling temperature range: pre-cooling by ambient and/or ‘high temperature’ refrigeration before final cooling can reduce refrigeration capital and running costs 8 Keep ‘hot’ and ‘cold’ fluids separate; do not mix water leaving the chiller with water returning from cooling circuits 9 Consider two‐stage or compound compression or economized screw compressors, rather than single stage compression, in low‐temperature systems where high temperature differences are inevitable Minimizing Temperature Differences 1 A vapor‐compression refrigeration system raises the temperature of the refrigerant from somewhat below the lowest process temperature (the evaporating temperature) to provide process cooling, to a higher temperature (the condensing temperature), somewhat above ambient, to facilitate heat rejection to the air or cooling water systems. Elevating Evaporating Temperature 1 Select a large evaporator to permit relatively low temperature differences between process and evaporating temperatures. Reducing Condensing Temperature 1 Air‐cooled evaporators usually have higher condensing temperatures, hence higher compressor energy use, and auxiliary power consumption, especially in low humidity climates. If a wet system is used, ensure adequate treatment to prevent growth of legionella bacteria. 2 Select a relatively large condenser to minimize differences between condensing and the heat sink temperatures. Condensing temperatures with air cooled or evaporative condensers should not be more than 10 K above design ambient condition, and a 4 K approach in a liquid‐cooled condenser is possible. 3 Refrigerant liquid lines should be connected via drop‐leg traps to the main liquid refrigerant line to ensure that hot gases flow to all condensers, in multiple condenser applications.

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4 Avoid head pressure control to the extent possible. Head pressure control maintains condensing temperature at, or near, design levels. Use of electronic rather than thermostatic expansion valves, and liquid refrigerant pumps can permit effective refrigerant circulation at much reduced condensing temperatures. 5 Site condensers and cooling towers with adequate spacing so as to prevent recirculation of hot air into the tower. Refrigerant Compression Efficiency 1 Consider turndown efficiency when specifying chillers. Variable speed control or multiple compressor chillers can be highly efficient at part loads. Compressed Air System: Measures Load Reduction 1 Examine each true user of compressed air to identify the air volume needed and the pressure at which this should be delivered 2 Do not mix high volume low pressure and low volume high pressure loads 3 Reduction opportunities:  Use air amplifier nozzles rather than simple open‐pipe compressed air jets,  Consider whether compressed air is needed at all,  Where air jets are required intermittently, consider operating the jet via a process‐related solenoid valve, which opens only when air is required,  Use manual or automatically operated valves to isolate air supply to individual machines or zones that are not in continuous use,  Implement systems for systematic identification and repair of leaks,  All condensate drain points should be trapped. Distribution 1 Use adequately sized distribution pipe work designed to minimize pressure losses.

3.3.8 Storm Water Management Storm water in the existing industrial complex is totally separate from the process liquid effluents. Process effluent is treated in effluent treatment plant and there-after, it gets mixed with storm water in final retention pond. Similarly the storm water of the new plant will also be separate from the process liquid effluent. The process effluent from

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IEFCL – Train2 fertilizer plant will be treated in waste water treatment facility of IEFCL – Train2 fertilizer plant and further sent to holding pond. Treated effluent water from holding pond will get mixed with storm water in final Retention Pond. Therefore the storm water from the new plant will be managed following recommendations indicated by “IFC Guidelines, Ed. April 30th, 2007 – Wastewater and Ambient Water Quality”. Applicable recommendations from the IFC Guideline shall be followed with respect to storm water management.

Storm water includes any surface runoff and flows resulting from precipitation, drainage or other sources. Typically storm water runoff contains suspended sediments, metals, soil coliform, etc.

Rapid runoff, even of uncontaminated storm water, also degrades the quality of the receiving water by eroding stream beds and banks.

In order to reduce the need for storm water treatment, the following principles, in compliance with IFC guidelines on Wastewater and Ambient water quality, would be applied in this project (Table 3.13):

Table 3.13: Measures to reduce the need of storm water treatment 1 Storm water will be separated from process and sanitary wastewater streams in order to reduce the volume of wastewater to be treated prior to discharge

2 Surface runoff from process areas or potential sources of contamination will be prevented

3 Where this approach is not practical, runoff from process and storage areas will be segregated from potentially less contaminated runoff 4 Runoff from areas without potential sources of contamination should be minimized (e.g. by minimizing the area of impermeable surfaces) and the peak discharge rate should be reduced (e.g. by using vegetated swales and retention ponds)

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5 Where storm water treatment is deemed necessary to protect the quality of receiving water bodies, priority will be given to managing and treating the first flush of storm water runoff where the majority of potential contaminants tend to be present; Normal case will consider the disposal of neutralized waste water and of de-oiled storm water to the existing plant pond.

6 Oil water separators and grease traps should be installed and maintained as appropriate at refueling facilities, workshops, parking areas, fuel storage and containment areas. Oil Skimmer has been foreseen inside each first rain sump to remove the majority of the oil, while the remaining will be removed through a Coalescing Plate Separator

7 Sludge from storm water catchments or collection and treatment systems may contain elevated levels of pollutants and should be disposed in compliance with local regulatory requirements, in the absence of which disposal has to be consistent with protection of public health and safety, and conservation and long term sustainability of water and land resources. Organic sludge will be incinerated in existing incinerators following existing SOP and ash will be analyzed as TCLP (Toxicity characteristics leaching procedure). Any spent catalyst containing zinc sulphide will be handled by competent person as per the guidelines of MSDS HSE (Health safety and Environment) procedure.

3.3.9 Gaseous waste For controlling gaseous waste in the new plants, a well-designed flare systems are incorporated to flare inadvertent release of Ammonia. The flare system is provided to dispose hydrocarbons & other fluids safely during normal operation, start up, and shut down & in case of emergency in complex.

3.3.10 Transport of Men, Materials and Equipment in the New Plant The construction activities will lead to increase traffic entering and leaving the Indorama Complex, in terms of number and type of vehicles, because of movement of employees and construction equipments/materials. Vehicular movement during this phase will include trucks, buses, minibuses and cars. Separate access and routes will be defined for movement of employees and materials. To keep controlled traffic around the Complex,

Chapter Three: Project Description 3-42 IEFCL -Train2 Fertilizer Project EIA Report all logistics elements of IEFCL-Train2 will use the existing Logistics Park (created at a convenient distance away from the Complex along the East West expressway) before being directed to the Plant/ Project site. During construction period it’s expected an additional daily traffic of about 75 trucks/containers for the transport of equipments/ materials (logistics) and 50 buses (3 shift) for the movement of Staff/Contract/Visitors. During operation phase the traffic will be slightly reduced: for the movement of Staff/Contract/Visitors.

There will be a dedicated parking area of trucks in front of main gate inside complex premise without constituting any nuisance to the highway.

3.4 DECOMMISSIONING ACTIVITIES The activities will involve demolition and site clean-up, disposal of wastes, demobilization and final site review, after a specific decommissioning plan will be reviewed and approved by FMENV, State Environmental Authorities.

3.5 PROJECT SCHEDULE Indorama Eleme Fertilizer & Chemicals Limited plans to execute the IEFCL-Train2 in Indorama Complex using local engineers and manpower, supported by foreign experts. The project schedule will be executed as follows:

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INDORAMA ELEME FERTILIZER & CHEMICALS LIMITED, PHC, NIGERIA IEFCL-Train2 OVERALL PROJECT SCHEDULE

DATES 2017 2018 2019 2020 2021 DURATION S No PROJECT A S O N D J F M A M J J A S O N D J F M A M J J A S O N D J F M A M J J A S O N D J F M (MONTHS) START FINISH -8 -7 -6 -5 -4 -3 -2 -1 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30 31 32 33 34 35 36 FLYING WORKS 2 1-Feb-18 31-Mar-18 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 1-Apr-18 30-Jun-19 1-April-18 NTP DETAILED ENGINEERING 30-Jun-19 24 1-Apr-18 31-Mar-20 PROCUREMNET 31-Mar-20 3 1-Apr-18 30-Jun-18 SITE GRADING MECH COMPLETION 26 1-Jul-18 31-Aug-20 SITE HAND OVER CONSTRUCTION 31-Aug-20 7 1-Feb-20 31-Aug-20 1-Apr-18 1-Aug-18 PRE-COMMISSIONING 4 1-Sep-20 31-Dec-20 M23 M26 M28 COMMISSIONING 1 FERTILIZER PROJET CRITICAL MILESTONES UTILITIES & GAS REQUIRED PRE-COMM COMPLETION 1 NOTICE TO PROCEED 1-Apr-18 8 PLOT PLAN ISSUUED - AFD 15-Jan-19 M23 IA PLANT AIR & POWER 31-Dec-20 2 START HAZAP STUDY 1-May-18 9 START ISOMETRIC ISSUE 1-Mar-19 M26 RAW WATER, CW, DMW &NITROGEN 3 30% MODEL REVIEW 1-Jul-18 10 START EQUIPMENT INSTALLATION 1-May-19 M28 NATURAL GAS 4 START FOUNDATION WORK 1-Jul-18 11 1ST DELIVERY OF LONG LEAD ITEM 15-Nov-19 5 P & ID ISSUED - AFD 1-Aug-18 12 NG FEED IN - AMMONIA PLANT 1-Aug-20 6 PLOT PLAN ISSUUED - AFD 15-Aug-18 13 MECH. COMPLETION- UREA PLANT 31-Aug-20 7 60% MODEL REVIEW 1-Sep-18 14 PLANT ACCEPTANCE UREA & COMPLETION 31-Dec-20

3 1-Jan-18 31-Mar-18 FINALISE EPC CONTRACT

STORAGE TANK 2.5 1-Apr-18 15-Jun-18 DETAILED ENGINEERING (Raw Water, Filter Water 8 1-Jun-18 31-Jan-18 PROCUREMENT & DM water) 15 1-Jul-18 30-Sep-19 CONSTRUCTION

1 1-Oct-19 30-Oct-19 COMM 3 1-Jan-18 31-Mar-18 FINALISE EPC CONTRACT WATER TREATMENT 2.5 1-Apr-18 15-Jun-18 DETAILED ENGINEERING 2 & 12 1-Jun-18 31-May-19 PROCUREMENT DM PLANT 15 1-Jul-18 30-Sep-19 CONSTRUCTION 2 1-Oct-19 30-Nov-19 COMM 1-Oct-19

INTERCONNECTING 6 1-Apr-18 30-Jun-18 DETAILED ENGINEERING PIPING, ELECTRICAL, 10 1-Jun-18 31-Mar-19 PROCUREMENT OF MATERIAL

UTILITYAUGVENTATION PROJECT INSTRUMENTATION ETC 10 1-Jul-18 30-Apr-19 FABRICATION, ERECTION & HOOK-UP 3 1-Jan-18 31-Mar-18 FINALISE EPC CONTRACT ROADS & DRAINS 28 1-Apr-18 31-Dec-20 LAYING OF ROADS & DRAINS IN PHASES LEGEND / ABBREVIATIONS DATE 30-Oct-17 ACTIVITY DURATION FOR PROJECT IS BASED ON THE SCHEDULE SUBMITTED BY TOYO AND ON INTERNAL ESTIMATES PREPARED BY REVIEWED BY APPROVED BY 1 CRTICAL PARTH DOC. NO Tr2-SCH OVER-001 THE ACTIVITY SCHEDULE MAY BE REVISED ON EPC FINALIZATION 2 NTP - NOTICE TO PROCEED REV. NO. 01 FLOAT AGAINST EACH PROJECT ACTIVITY MAY BE CHANGE, IF THE PROJECT SCHEDULE UNFER GO REVISION, IF ANY DR. M.K.JAIN MR. S.M.MOHAN MR. P.J.S.BAJWA

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IEFCL Train2 Fertilizer EIA Report

CHAPTER FOUR DESCRIPTION OF THE ENVIRONMENT

4.1 GENERAL The objective of the environmental baseline description is to establish the condition of the various environmental components that are likely to be affected by the proposed project against future occurrences as a result of the project activities. This would provide the basis for determining the impacts of the proposed project on the environment as well as the determination of mitigation measures. In this ESIA the environment is classified as biophysical, social and health. The baseline conditions of the biophysical environment (physical, chemical and biological) of the proposed field development project area, and the socio-economic and health conditions of the communities within the project area are described.

4.1.1 Baseline Data Acquisition Methods The approach adopted was to obtain physical and biophysical baseline data from desktop, field and laboratory studies, interviews and consultations with individuals / representatives of the host communities of the proposed project area. For socio-economic & health studies, structured questionnaires were administered to a probability sample of households. This approach would provide adequate information for establishing the baseline status of the environment of the study area. The study consisted of a one-season field sampling campaign, which took place between 29 to 30th September, 2017 (Wet Season), while leveraging on the results of the Indorama Eleme Fertilizer & Chemicals Limited-Train1 EIA carried out in 2010 for the dry season data.

4.1.2 Description of Sampling Locations The Sampling points were geo-referenced by means of Global Positioning System (GPS) on the field. Judgment sampling was applied in the selection of study stations, taking into account ecological features, geographical location of communities and control points in apparently undisturbed areas. The universe of households was obtained from listing by guides and assigned field assistants.

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IEFCL Train2 Fertilizer EIA Report

The map showing the study area with the sampling stations are shown in Appendix 4.1. The Local Government Area and communities (Table 4.1.1) were identified within the defined study boundary. Table 4.1.1: Study Communities

STATE (1) LOCAL GOVERNMENT AREA (2) COMMUNITY (4)

Rivers State Eleme Aleto

Agbonchia

Akpajo

Obio-Akpor Elelenwo

4.1.3 Spatial Boundary for the Study Data gathering for the baseline studies considered the following spatial boundaries:  2km radius for biophysical sampling  4km spatial boundary for socio-economic and health assessment  5km for Control samples  Geo-referencing of all sample stations.

4.1.4 Environmental components of the Study A comprehensive description of the baseline conditions of the proposed project area was undertaken. The scope covered:  Meteorology  Air Quality and Noise  Soil, Land use and land cover  Vegetation and Wildlife  Geology/Hydrogeology  Surface water and sediment quality  Groundwater Quality  Socio-economics  Human Health

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4.1.5 Study Design and Methodology The study approach included  Review of existing literature and secondary data  Ecological baseline data gathering in line with the approved Terms of Reference (TOR) for the EIA

Biophysical Components Field sampling and observations involved using standard methods in-situ measurements with appropriate equipment of certified calibration; laboratory analysis of samples using standard methods; quality assurance and quality control.

Socioeconomics and Health Components Key informant interviews, Focus Group Discussion (FGD), direct observation, Administration of structured questionnaires and Collection of secondary data.

The field procedures adopted for data collection are summarized in Appendix 4.2 and the instruments used for sampling, measurement and analysis are summarized in Table 4.1.2.

Table 4.1.2 Environmental Components and Methods/Instruments used for sampling / measurement / analysis ENVIRONMENTAL PARAMETER EQUIPMENT UNIT COMPONENT METEOROLOGY Temperature Traceable Thermometer C Wind speed  Direction Skye Master Anemometer & m/s, wind Vane Humidity, Atmospheric Pressure Skye Master Mini Weather % Station

AIR QUALITY Suspended Particulate Matter Met One Instrument Aerosol mg/m3 Mass Monitor

Nitrogen Oxides Testo 350 XL Gas Analyser ppm Sulphur Oxides Testo 350 XL Gas Analyser ppm Carbon Monoxides Testo 350 XL Gas Analyser ppm VOC/HC Testo 350 XL Gas Analyser ppm Heavy Metals Air metrics Minivol Sampler/ ppm

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ENVIRONMENTAL PARAMETER EQUIPMENT UNIT COMPONENT Atomic Absorption Spectrometry NOISE Sound level Extech Sound Meter dB(A)

SOIL Sampling Stainless steel auger pH Hannah pH meter Electrical conductivity Hannah conductivity meter. µS/cm Soil Texture Particle Size Matrix Organic carbon Wet combustion method % Heavy metals Digestion/Atomic Absorption mg/kg Spectrophotometry Total Hydrocarbon Content Extraction / IR mg/kg Spectrophotometry

VEGETATION Quadrant, Binoculars

GROUNDWATER Niskin water sampler & ISCO Borehole Sampler Temperature Eco Testr pH/temperature oC Meter pH Eco Testr pH meter Total, Dissolved and Suspended ExTech Conductivity/TDS Meter mg/l Solid Total Alkalinity HACH Digital Titration method mg/l Dissolved Oxygen ExTech DO Meter mg/l

Biological oxygen Demand (BOD5) Winkler method mg/l Total Hydrocarbon Content (THC) Extraction / Spectrophotometer mg/l Conductivity Ex Tech Conductivity Meter. Heavy metals Flame Photometry / Atomic mg/l Absorption Spectrometry

MICROBIOLOGY Total heterotrophic bacteria, Composite samples for fungi, hydrocarbon Utilizing laboratory analysis bacteria and fungi, total and faecal coliforms.

WATER USE Traditional use of rivers and Direct observation/ water bodies (navigation, sand interviews mining, food processing, aquaculture, domestic etc.)

WILDLIFE Conservation status (rare, In situ observation, interviews,

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ENVIRONMENTAL PARAMETER EQUIPMENT UNIT COMPONENT threatened and endangered secondary data species), conservation areas (forest reserves etc.), environmentally sensitive areas – wetlands and swamps), local conservation practices.

GEOLOGY Profile, type and composition In situ observation, drilling, laboratory analysis, reporting

SOCIO-ECONOMIC Social Infrastructure Cultural Key informant interviews, Focus STUDIES Properties, Natural Resources Group Discussion (FGD), direct and Land Use, Perception of the observation, Administration of project, The role of women and structured questionnaires and children, Physically Challenged, Collection of secondary data. Social Structure and Organization, Vehicular Traffic Analysis, Sex Trade

HEALTH STUDIES Demographic profile of the Key informant interviews, FGD, Communities, Administration of structured Morbidity/Mortality Patterns, questionnaire and interviews, Healthcare facilities, Nutritional Physical examination of Status of Under-fives and the volunteers, Walk-through general population, Maternal and survey and Collection of Child Health, Knowledge, Attitude secondary data. Practice and Behaviour (KAPB), Environmental health factors,

4.1.6 Quality Assurance / Quality Control The QA/QC programmes covered all aspects of the study, including sample collection and handling, laboratory analyses, generation of data and coding, data storage and treatment as well as report preparation. The quality assurance programme used in the fieldwork and laboratory analyses is in accordance with international and National regulatory recommendations such as:  Ensuring that only experienced and qualified personnel were engaged in the study

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 Carrying out field calibrations of equipment and running distilled water blanks to reduce errors that could arise from field measurements.  Ensuring that replicate samples were collected and used as checks of instrument performance.  Carrying out field analytical operations in a defined sequence to avoid cross contamination of instruments.  The collected samples were submitted in due time to FMEnv approved laboratories, which are well equipped with latest sophisticated instruments and managed by well experienced professionals. Parameters such as temperature, pH, turbidity, electrical conductivity and dissolved oxygen were determined in situ because of their rapid change on storage as samples could be subject to microbial degradation and transformation. They were therefore analysed at minimum time after collection.

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4.2 METEOROLOGY

4.2.1 Site Specific Micro Meteorology The Climate assessment for the study environment tends to highlight the atmospheric pattern of the study area. The assessment of climatic parameters such as rainfall, temperature, wind speed & direction, relative humidity and cloud cover are important baseline variables for any proposed or ongoing project activity in any place. According to Ayoade (2008), the weather condition of study environment is determined by the monsoon; a seasonal wind shift that brings rain (wet monsoon) via South-Westerly wind between March and early November and usher in dry season (dry monsoon) via North-Easterly wind between December and February. Rainfall is the main climatic variable and there is marked alternation of wet and dry seasons in the study area. Two air masses controls rainfall – moist Northward moving maritime air coming from the Atlantic Ocean and the dry continental air coming from the African Landmass. The climate of Niger delta is affected by ocean and atmospheric interactions both within and outside its environment, in which the Inter‐Tropical Convergence Zone (ITCZ) plays a controlling factor. The movement of the ITCZ is associated with the warm humid maritime Tropical air mass with its South-Western winds and the hot and dry continental air mass with its dry North- Easterly winds.

The micro-meteorological data recorded in study environment are summarized in Table 4.2.1.

Table 4.2.1: A 24-hour weather pattern recorded within study area. Hours Air R/Humidity Wind Pressure Cloud Weather (GMT) Temp. (%) Speed Direction (mbar) Cover Date: 29th, (oC) (m/sec) (Oktas) September, 2017 17:00 31.6 69 2.6 SE 1025.0 5 S 18:00 29.7 76 2.0 SW 1025.5 5 PS 19:00 28.0 83 1.5 SE 1025.7 NT Slight Wind

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20:00 27.0 86 1.0 SE 1026.2 NT Cool 21:00 26.5 87 0.7 SW 1027.7 NT Cool 22:00 26.0 92 0.5 SE 1027.5 NT Cool 23:00 25.5 93 0.5 SW 1027.4 NT Cool 00:00 25.0 93 Calm Calm 1027.4 NT Calm 01:00 24.5 94 Calm Calm 1025.4 NT Calm 02:00 24.0 94 1.0 SW 1025.4 NT Slight Rain 03:00 23.0 95 1.4 SW 1025.2 NT Slight Rain 04:00 23.0 95 1.3 SW 1025.2 NT Slight Rain 05:00 22.5 96 1.5 SE 1025.3 NT Slight Wind 06:00 22.5 96 1.6 SW 1025.3 6 Slight Wind 07:00 23.5 94 0.9 SE 1025.9 6 PC 08:00 25.5 87 1.0 SE 1026.0 6 PC 09:00 27.8 75 1.2 SW 1027.2 6 PC 10:00 29.5 65 1.5 SW 1027.8 5 PS 11:00 31.5 65 3.0 S 1027.8 5 S 12:00 33.4 60 3.5 SW 1027.4 4 S 13:00 32.8 63 3.3 SW 1027.3 5 S 14:00 33.1 61 3.2 SW 1026.7 5 S 15:00 33.3 61 3.1 SW 1026.9 5 S 16:00 33.2 61 3.2 SE 1026.7 5 S Mean 27.6 81 1.8 SW 1026 5 GPS Coordinates: Latitude N04o 48’ 57.6” Longitude E007o 05’ 52.8” *S-Sunny, **PS- Partly sunny, ***PC- Partly cloudy, ****NT-Night time

Rainfall Pattern The study area is situated within the tropical wet climatic belt. In this belt, rainfall variation is the most important parameter for the determination of season. In general, two seasons are characteristic of the climate in the region, namely the dry and wet seasons. In wet season, the annual distribution starts with the initial rains in March, which ceases in late November. Typically, there are two major seasons, sometimes, heavier rainfall than usual may occur and

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IEFCL Train2 Fertilizer EIA Report the rain is extended into the dry season and often the August break may not even occur. Rainfall is the most important element of climate change and water resources potential. It impacts almost all areas of human life such as agriculture, health, transportation, electricity etc. The amount and distribution of rainfall in the study area is such that it plays an important role in moving pollutants from the atmosphere to other spheres of the environment. The mean annual rainfall for the study environment is above 2300mm. The data retrieved from close meteorological station and shown in Table 4.2.2, present the mean monthly rainfall distribution for 30 years (1985-2015) in the study area. Average highest rainfall peaks were attained in September (370mm), July (364mm) and August (325mm). Lowest rainfall values were attained in January (15.3mm) and December (19.2mm). It should be noted that rainfall is very important in managing construction projects because of its power to cause erosion and erode soil particles from ground level surfaces.

Air Temperature Maximum and minimum onsite temperature was 33.4C measured at 12:00GMT and the minimum recorded was 22.5C at 05:00 & 0600 GMT (Table 4.2.1). Analysis from the macro data shows that the months of July-September recorded lower temperatures (28-29C) due to rainy periods while the months December to March recorded higher temperatures (32-34C) due to intense solar radiation prevalent in the dry season (Table 4.2.2). Uko and Tamunobereton-Ari, (2013) noted that the average maximum and minimum temperatures during the dry and wet seasons are within 31-33oC and 21-23oC as well as 25-33oC and 18-23oC respectively. The degree of air temperature is dependent on the amount of solar radiation received, atmospheric conditions, such as cloud cover and humidity, which trap heat and this impacts on the stability pattern of the atmosphere in the area. Port Harcourt exhibit a very stable stability class F at nights that inhibits emission dispersion and slightly unstable/moderate stability classes C-B during the day periods that enhances emission dispersions (Edokpa and Nwagbara 2017). Air temperature also affects nearly all other weather parameters. For instance, air temperature affects: the rate of evaporation, wind speed and direction, precipitation patterns as well as the unstable, stable and neutral conditions of the atmospheric

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IEFCL Train2 Fertilizer EIA Report environment. Measuring air temperature is critical to the proper identification of the micro and macro environment of living organisms. It is especially critical for researchers in the animal and biological sciences since ambient temperature can influence their physiological, nutritional and behavioral status. The study environment is bounded heavily by open vegetation areas and this modifies ambient temperature. Ansari (2003) noted that the major parts of a healthy environment are vegetation associated with area. He emphasized that vegetation improves the environment by lowering the maximum temperature and increasing the minimum temperature most especially in locations of increased elevation. When air passes through vegetation it cools and obtains moisture which when mixed with the open environment reduces temperature thereby generating was is referred to as local precipitation (Ansari, 2003). Ayoade (2004) highlighted that the features which impact the distribution of temperature at any location include: the amount of insulation received, nature of the surface, distance from water bodies, relief, nature of prevailing winds and ocean currents. Figures 4.2.1 to 4.2.4 shows the processed satellite data for average surface temperature for 0000, 0600, 1200 and 1800 hours in the study environment for July 2017.

Figure 4.2.1: Average 0000Hr Air Temp. Pattern for Study Area in July 2017.

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Figure 4.2.2: Average 0600Hr Air Temp. Pattern for Study Area in July 2017.

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Figure 4.2.3: Average 1200Hr Air Temp. Pattern for Study Area in July 2017.

Figure 4.2.4: Average 1800Hr Air Temp. Pattern for Study Area in July 2017.

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Temp R/H

40 100

90 35 80

30

70 25 60

20 50

40

15 Air Temperature Air (oC) 30 Relative Humidity (%) 10 20 5 10

0 0

7:00 0:00 1:00 2:00 3:00 4:00 5:00 6:00 8:00 9:00

17:00 18:00 19:00 20:00 21:00 22:00 23:00 10:00 11:00 12:00 13:00 14:00 15:00 16:00 Hour

Figure 4.2.5: Diurnal temperature and relative humidity variations during fieldwork

Relative Humidity The maximum relative humidity observed during fieldwork was 96%, recorded at 05:00- 06:00GMT. The minimum recorded was 60% at 12:00 GMT (Table 4.2.1). As ambient temperature increases, percentage humidity decreases and vice-versa. Relative humidity which measures water vapour in the atmosphere is noted to be low during dry season and high during the peak of rainy season due to the influence of moisture laden South-Westerly winds as seen from the macro average monthly results. Also relative humidity was low during the afternoons and maximum at nights as indicated from the field data (Table 4.2.1). A 30-year mean monthly relative humidity analysis shows that the study environment has high relative humidity throughout the year with peaks during the wet season (Table 4.2.2). Oluyole et al., (2013) disclosed that average annual relative humidity for the area is above 80%. Figure 4.2.5 shows the observed diurnal relative humidity and temperature values moving in opposite directions.

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Due to the moist nature of the atmospheric environment in the study area, relative humidity is always high throughout the years.

Table 4.2.2: Average Weather Trend for Port Harcourt (1985-2015). Average Rainfall Cloud Pressure R/H Wind Wind S/N0 Month Temp (mm) Cover (mbar) (%) Speed Dir. (OC) (oktas) (m/s) 1 January 33.5 15.3 6.8 1006.5 72 2.8 NE 2 February 34.1 74 6.8 1005.8 77 2.5 SW 3 March 33.7 92.7 6.9 1005.6 81 3.6 SW 4 April 32.6 143 6.9 1005.7 83 3.6 SW 5 May 32.1 247.4 6.9 1007.4 87 3.7 SW 6 June 30.4 310 7 1008.4 89 3.8 SW 7 July 28.3 364 7 1009.7 91 4.2 SW 8 August 29.0 325 7 1009.6 91 4.1 SW 9 September 28.6 370 7 1008.9 91 4.3 SW 10 October 30.8 242 6.9 1007.7 88 3.5 SW 11 November 32.1 72.8 6.8 1006.8 84 2.6 SW 12 December 33.4 19.2 6.8 1006.7 73 2.4 NE Source: NIMET, Port Harcourt.

Wind Speed/Direction Average micro wind speed measurement during field survey was 1.8 m/sec (Table 4.2.1). Largely, wind speeds were moderate during the day and lesser at dawn. It was calm at the hour 00:00-01:00GMT of dawn. The prevailing wind direction was the South-Westerly winds as presented in the wind rose below (Figure 4.2.6). This implies that any released air emissions will be blown towards the North-East direction of the study environment. Figure 4.2.7 shows the direction in which the wind is heading to. Wind speed classification shows that range 0.5 - 2.1m/s constituted 62.5% while the range 2.1-3.6m/s constituted 25% (Figure4.2.8). It is however the period of calm that is of importance in evaluating emissions (8.33%). If the air is calm, pollutants cannot disperse, and then the concentration of these pollutants will build up. On the other hand, when strong, turbulent winds blow, pollutants disperse quickly, resulting in

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IEFCL Train2 Fertilizer EIA Report lower pollutant concentrations. In pollution, meteorology calms are associated with inversions (temperature increasing with height). Inversion may result in fumigation; meaning that emissions are trapped at ground level close to their source as against other situations where it is dispersed and diluted much more easily. Inversion is widely known to be frequent during the early hours of the day. A 30-year mean macro data shows that wind speed over the study environment is generally minimal and this signifies a low to moderate dispersive potential of the local atmosphere.

Figure 4.2.6: Diurnal wind rose pattern of project area during fieldwork.

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Figure 4.2.7: Study Area Wind Direction Coming from SW/SE.

Figure 4.2.8: Diurnal wind speed record for project area during fieldwork

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Cloud Cover Mostly the weather condition during the period of field data collection was partly cloudy and the average cloud cover was 5oktas. Maximum cloud cover (6oktas) was observed during the morning period (06:00-09:00GMT). Average cloud cover for the area from 1985-2015 shown in Table 4.2.2, indicates values above 6 oktas throughout the year. This long term trend signifies the high rate of rising moist air mass due to the abundant water content in the study area which gives rise to convective clouds. It has been revealed (Edokpa, 2017) that the lapse rate pattern for the area under review tends towards the moist adiabatic lapse rate (MALR). High amounts of cloud inhibit instability that decreases the dispersion of plumes and lower amounts promote unstable conditions which enhances atmospheric dispersion of plumes. Cloud cover is prominent during rainy periods and minimal during dry seasons which allow the penetration of solar energy leading to increased heat during these periods.

Atmospheric Pressure Atmospheric pressure at sea level measured during the period of field survey was between 1025-1027mbar. An important characteristic of the atmosphere is its pressure as it often determines wind and weather pattern across an area. The normal range of the earth’s air pressure is from 970mbar to 1050mbar. Air pressure differences across various locations are the results of unequal heating across surfaces. This leads to wind blowing from high pressure areas towards low pressure areas. High pressure areas are usually associated with clear weather while low pressure areas are associated with unstable weather conditions which generate precipitation.

4.3 AIR QUALITY AND NOISE

4.3.1 Air Quality

Table 4.3.1: Wet season Baseline Air Quality of Project Area

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SO2 NO2 CO H2S THC VOCs NH3 TSP PM 10 PM2.5 (µg/m3) (µg/m3) (µg/m3) (µg/m3) (µg/m3) (µg/m3) (µg/m3) (µg/m3) (µg/m3) (µg/m3) Location/Parameter

X1 Aleto Community 0.00 0.00 0.00 0.00 0.00 15.00 0.32 11.00 10.00 1.00

X2 IEFCL Flare Area 0.00 0.00 0.00 0.00 20.00 9.00 0.20 27.00 18.00 9.00

X3 IEFCL NG Receipt facility Area 0.00 2.00 1.30 0.00 0.00 25.00 0.30 15.00 10.00 5.00

X4 IEFCL Urea bagging Plant 0.00 0.00 0.00 0.00 10.00 15.00 0.01 8.00 5.00 3.00

X5 IEFCL Weigh Bridge 2.60 2.00 0.00 0.00 20.00 3.50 0.04 59.00 39.00 20.00

X6 IEFCL Main Gate 0.00 0.00 2.60 0.00 10.00 10.00 0.03 47.00 31.00 16.00

X7 Akpajo Community 5.40 0.00 3.80 0.00 0.00 5.00 0.00 30.00 19.00 11.00

Control Agbonchia Njuru (Control 1) 0.00 0.00 1.30 0.00 0.00 10.00 0.18 20.30 13.80 6.50 1 Control Rumukrushi Town (Control 1) 0.00 0.00 0.00 0.00 0.00 0.00 0.00 23.00 15.00 8.00 2 1.0- Range 0.0-5.4 0.0-2.0 0.0-3.8 0.0 0.0-20.0 0.0-25.0 0.0-0.32 8.0-59.0 5.0-39.0 20.0

Mean 0.9 0.4 1.0 0.0 6.7 10.3 0.1 26.7 17.9 8.8

Std. dev. 1.90 0.88 1.40 0.00 8.66 7.44 0.13 16.79 10.81 6.09

75th percentile (upper 1.00 1.00 1.50 0.00 6.20 8.70 0.06 37.00 19.00 11.00 quantile)

FMEnv limit 260 75-113 22.8 N/A 3-160 6000 0.5-1.0 250 N/A N/A

IFC limit 20 200 N/A N/A N/A N/A N/A N/A 50 25

Table 4.3.2: Dry season Baseline Air Quality of Project Area

3 Location/Parameter SO2 NO2 CO H2S THC(µg/m ) NH3 VOCs TSP PM10 PM2.5 (µg/m3) (µg/m3) (µg/m3) (µg/m3) (µg/m3) (µg/m3) (µg/m3) (µg/m3) (µg/m3)

X1 Aleto Community 0.00 0.00 0.00 0.00 7.10 20.00 13.00 7.00 0.00 20.00

X2 IEFCL Flare Area 13.10 18.80 11.50 0.00 7.10 32.00 20.00 12.00 0.10 10.00

X3 IEFCL NG Receipt facility 0.00 18.80 0.00 0.00 7.10 31.00 17.00 14.00 0.20 5.00 Area X4 IEFCL Urea bagging 0.00 0.00 0.00 0.00 0.00 20.00 11.00 9.00 0.00 10.00 Plant X5 IEFCL Weigh Bridge 13.10 18.80 11.50 0.00 0.00 55.00 33.00 22.00 0.20 5.00

X6 IEFCL Main Gate 13.10 18.80 11.50 0.00 7.10 67.00 46.00 21.00 0.00 10.00

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X7 Akpajo Community 10.50 9.40 9.20 0.00 14.30 47.00 30.00 17.00 0.00 20.00

Control Agbonchia Njuru 13.10 3.80 0.00 0.00 7.10 41.00 23.00 18.00 0.20 10.00 1 (Control 1) Control Rumukrushi Town 0.00 0.00 0.00 0.00 0.00 50.00 37.00 13.00 0.00 0.00 2 (Control 1) Range <0.01- <0.01- <0.01- 0.0 <0.01-14.3 <0.01- <0.01- 20.0-67.0 11.0- 7.0- 13.1 18.8 11.5 0.2 20.0 46.0 22.0 Mean 7.0 9.8 4.9 0.0 5.5 40.3 25.6 14.8 0.1 10.0

Std dev. 6.68 9.00 5.80 0.00 4.76 16.00 11.75 4.14 0.10 6.61

75th percentile (upper 23.40 10.70 11.50 0.00 16.80 0.01 42.50 33.00 33.00 18.00 quantile) FMEnv Limit 260 75-113 22.8 N/A 3-160 0.0-1.0 6000 250 N/A N/A

IFC limit 125 200 N/A N/A N/A N/A N/A 50 25

Sources of dry season data: IEPL, (2012 to 2016)

Sulphur dioxide (SO2)

SO2 is an important oxide of sulphur as a primary pollutant, and is formed from the combustion of sulphur containing hydrocarbon fuels containing of sulphur in certain industrial processes. Fossil fuel combustion by electrical utilities, industries and automobiles are the primary sources of sulphur dioxide. Emissions of sulphur compounds (such as sulphur dioxide) are associated with industrial operations like combustion processes associated with the extraction, upgrading, and refining of bitumen, electricity and steam generation Kindzierski et al., (2009). A range of chronic and acute health impacts has been associated with human exposure to sulphur dioxide

(WHO, 1999; Davis and Cornwell, 2008). SO2 can irritate the respiratory system, cause shortness of breath, chest tightness and wheezing. Results (shown in Tables 4.3. 1and Figure 4.3.1) obtained in the wet season showed that concentrations of sulphur dioxide ranged from <0.01µg/m3 to 5.4µg/m3 with mean deviation of 0.9±1.90µg/m3; while secondary data (shown in Table 4.3.2) obtained in the dry season showed that sulphur dioxide ranged in value from <0.01µg/m3 to 13.1µg/m3with mean deviation of 7.0±6.68µg/m3. The mean values are below both FMEnv and IFC limits. Concentration levels of

SO2 in proposed project area are shown in Figure 4.3.1 and in Tables 4.3.1 and 4.3.2 for both the dry and wet seasons respectively. These results represent the baseline sulphur dioxide

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IEFCL Train2 Fertilizer EIA Report concentration in ambient air of the proposed project area before construction and operation of the proposed project.

Nitrogen Dioxide (NO2) Nitrogen dioxide is a product of high temperature combustion in vehicle engines, power plants, domestic fires and industrial facilities. Exposure to nitrogen dioxide has been associated with adverse health effects (WHO, 1999). At very high concentrations, NO2 exposure can result in rapid and severe lung damage. It can also affect the liver, spleen and blood. It can also aggravate lung diseases leading to respiratory symptoms and increased susceptibility to respiratory infection. People with asthma or chronic obstructive pulmonary disease are more susceptible at lower concentrations. Based on the best available clinical evidence, a 1-hour guideline of 200μg/m3 has been set by World Health Organization (WHO, 1999).

3 3 Field measurement shows that concentrations of NO2ranged from <0.01µg/m to 2.0µg/m with mean deviation of 0.4±0.88µg/m3in the wet season (Table 4.3.1 and Figure 4.3.2).The dry season result from previous studies conducted in the area (Table 4.3.2)) shows that NO2 ranged from <0.01µg/m3 to 18.8µg/m3 with mean deviation of 9.8±9.00µg/m3 (Table 4.3.2 and Figure 4.3.2). The dry and wet season values are within both FMEnv and IFC limits. The concentration levels of this pollutant were low in many sampling locations in the wet season in comparison to the dry season. This is due to heavy downpour. Measured values are shown in Figure 4.3.2.

These values are the baseline NO2 concentration in ambient air of the area before construction and operation of the proposed project.

Carbon Monoxide (CO) Carbon Monoxide is a product of incomplete combustion (oxidation) of fossil fuels or hydrocarbons. Main sources of CO in ambient air include road transport and industrial combustion (Kindzierski et al., 2009; EEA, 2013). The binding of carbon monoxide (CO) with hemoglobin to form carboxy-hemoglobin (COHb) reduces the capacity of blood to carry oxygen, and the binding with other haem proteins is directly related to changes in the functions

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Figure 4.3.2: Concentrations of Nitrogen dioxide in proposed project area IEFCL Train2 Fertilizer EIA Report of affected organs, such as the brain, cardiovascular system, exercising skeletal muscle and the developing fetus. At very high concentrations, well above normal ambient levels, CO causes death (WHO, 1999).

The wet season CO values ranged from <0.01µg/m3 to 3.8µg/m3 with mean deviation of 1.0±1.40µg/m3(Table 4.3.1 and Figure 4.3.3); while the dry obtained from previous study (Table 4.3.2) ranged from <0.01µg/m3 to 11.5µg/m3 with a mean deviation of 4.9±5.80µg/m3 (Table 4.3.2 and Figure 4.3.3). These values are below the FMEnv limit and represent baseline CO concentration in ambient air of the proposed project area. The wet and dry seasons concentrations of CO measured in the proposed project area are shown in Figure 4.3.3.

Hydrogen Sulphide (H2S) Hydrogen Sulphide is an extremely toxic, odorous, corrosive flammable gas. Anthropogenic sources of H2S in ambient air include natural gas, petroleum refining, coke ovens exhaust gas and nylon & rayon manufacturing (Flagan and Seinfeld, 1988). The concentrations of H2S in proposed project area were generally low in wet and dry seasons (<0.01µg/m3). Similar results were obtained from previous studies conducted in the area in dry seasons (Table 4.3.2).

Ammonia (NH3) Ammonia is a colorless gas with pungent odor. Main sources of ammonia in ambient air include agricultural activities, manure storage, slurry spreading, and the use of synthetic nitrogenous fertilizers (Davis and Cornwell, 2008). Exposure to high levels of ammonia may irritate, eyes, throat, and lungs and cause coughing. People with asthma may be more sensitive to breathing ammonia than others. NH3 may pose a serious threat to the health of the birds such as; increase risk of skin burns, high incidence of contact dermatitis: foot, hock and breast burns that can be a gateway for bacteria causing further health problems to the birds (Davis and Cornwell, 2008).

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The concentrations of ammonia measured in the wet season ranged from <0.01µg/m3 to 0.32µg/m3 with a mean deviation of 0.1±0.13µg/m3 (Table 4.3. 1 and Figure 4.3. 4); while the dry season values obtained from previous study ranged from <0.01 to 0.20µg/m3 with a mean deviation of 0.1±0.10µg/m3 (Table 4.3.2 and Figure 4.3.4). The wet and dry seasons concentrations of NH3 measured in the project are shown in Figure 4.3.4. These results represent baseline NH3 concentration in ambient air of the proposed project area.

Total Hydrocarbon (THC) Total hydrocarbon in ambient air comprises of aromatic hydrocarbons (benzene rings with carbon atoms) and aliphatic hydrocarbons (benzene rings with no carbon atoms). Methane (CH4) constitutes by far the largest form (by mass) of total hydrocarbon in ambient air (Kindzierski et al., 2009). Background hydrocarbons are primarily composed of CH4 with a small contribution from non-methane hydrocarbons (NMHCs). THC is produced by both anthropogenic and biogenic (natural) sources. Major-anthropogenic sources include agricultural activities, road transportation and industrial processes. Methane is an important greenhouse gas, and also contributes to the formation of ground level ozone (Kindzierski et al., 2009).

Health effects associated with a single exposure to hydrocarbons are asphyxiation, narcosis (i.e. depression of the central nervous system; anesthesia), cardiac arrest and aspiration (WHO, 1999). The acute health effects of hydrocarbon mixtures are generally associated with exposure concentrations at thousands of ppm.

The wet season concentrations of total hydrocarbon monitored in proposed project area ranged from <0.01µg/m3 to 20.0µg/m3 with mean a deviation of 6.7±8.66µg/m3 (Table 4.3.1 and Figure 4.3.5); while the dry season values obtained from previous studies (Table 4.3.2) ranged from <0.01µg/m3 to 14.3µg/m3 with a mean deviation of 5.5±4.76µg/m3 (Table 4.3.2 and Figure 4.3.5). These values are within FMEnv stipulated limit. Concentration levels of total hydrocarbons in proposed project area are shown in Figure 4.3.5 form baseline THC concentration in ambient air of the proposed project area.

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Volatile Organic Compounds (VOC) VOC are a large group of carbon-based chemicals that have a high vapour pressure and easily evaporate at room temperature conditions. They include Acetone, Benzene, Ethylene glycol, Formaldehyde, Methylene chloride, Toluene, Xylene, 1,3-butadiene etc. VOC are emitted as gases from certain solids or liquids. VOC include a variety of chemicals, some of which may have short- and long-term adverse health effects. VOC are emitted by thousands of products including: paints and lacquers, paint strippers, cleaning agents, pesticides, furniture and furnishing items, office equipment such as copiers and printers, correction fluids and carbonless copy paper, graphics and craft materials including glues and adhesives, permanent markers, and photographic solutions.

VOC are known to cause Eye, nose, and throat irritation; headaches, loss of coordination, nausea; damage to liver, kidney, and central nervous system. Some organics can cause cancer in animals; some are suspected or known to cause cancer in humans (WHO, 1999). The principal harmful effects of VOC are toxicity, possible contribution to smog via photochemical reactions in the atmosphere, and possible contribution to the “greenhouse effect” and consequent global warming (Davis and Cornwell, 2008),

VOC concentrations measured in the project area in the wet season ranged from <0.01µg/m3to 25.0µg/m3 with a mean deviation of 10.3±7.44µg/m3 (Table 4.3.1 and Figure 4.3.6), while the dry season values obtained from previous studies (Table 4.3.2) ranged from <0.01µg/m3to 20.0µg/m3 with a mean deviation of 10.0±6.61µg/m3 (Table 4.3.2 Figure 4.3.6). Concentration levels of VOC shown in Figure 4.3.6 are well below limit and represent baseline VOC concentration before construction and operation of the proposed project.

Total Suspended Particulate Matters (TSP) The term particulate matter (PM) describes materials that are suspended in the air. PM is a mixture of aerosol particles (solid and liquid) covering a wide range of sizes and chemical composition. These are light particles (Usually dust, fly ash) or other materials found suspended

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IEFCL Train2 Fertilizer EIA Report in the atmosphere and carried around by the wind. TSP is either directly emitted as primary particles or it is formed in the atmosphere from emissions of SO2, NOx, NH3 and Non methane volatile organic compounds (NMVOCs). TSP is emitted from many anthropogenic sources, including both combustion and non- combustion sources. Major sources of TSP include transportation (diesel vehicles), combustion processes, refining of bitumen and coal-burning power plants(Kindzierski et al., 2009).Adverse health effects include aggravation of respiratory problems, cardiovascular and lung diseases, heart attacks and arrhythmias. Prolong exposure to TSP can lead to premature death (WHO, 1999; Kindzierski et al., 2009).

Concentrations of TSP obtained in the wet season ranged from 8.0µg/m3 to 59.0µg/m3 with a mean deviation of 26.7±16.79 µg/m3 (Table 4.3.1 and Figure 4.3.7), while the dry season values obtained from previous studies (Table 4.3.2) ranged from 20.0µg/m3 to 67.0µg/m3 with a mean deviation of 40.3±16.00µg/m3 (Table 4.3.2 and Figure 4.3.7). Concentrations of TSP measured in project area are below FMEnv limit and represent baseline TSP concentration of the project area before construction and operation of the proposed project.

PM10Particulate Matter (Respirable Suspended Particulate matter, RSPM)

PM10 refers to particulate of size less than 10 microns (≤10 µm) in aerodynamic diameter. PM10 particulate matter is also known as respirable suspended particulate matter because it is breathe out by human beings. It has the same sources and effects as TSP.

3 3 Concentrations of PM10 obtained in the wet season ranged from 5.0µg/m to 39.0µg/m with a mean deviation of 17.9±10.81µg/m3 (Table 4.3.1 and Figure 4.3.8), while the dry season values obtained from previous studies (Table 4.3.2) ranged from 11.0µg/m3 to 46.0µg/m3 with a mean 3 deviation of 25.6±11.75µg/m (Table 4.3.2 and Figure 4.3.8). Concentrations of PM10 measured in the proposed project area are below IFC limit of 50µg/m3as shown in Figure 4.3.8 and represent baseline condition of the project area before construction and operation of the proposed project.

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PM2.5 Particulate Matter (Inhalable Suspended Particulate matter, ISPM)

PM2.5 refers to particulate matter with size less than 2.5 microns (≤2.5 µm) in aerodynamic diameter. It also called inhalable suspended particulate matter because it can penetrate through the upper respiratory track into the lungs. It has the same sources and effects as TSP.

3 The wet season concentrations of PM2.5 obtained in the project area ranged from 1.0µg/m to 20.0µg/m3 with a mean deviation of 8.8±6.09µg/m3 (Table 4.3.1 and Figure 4.3.9), while the dry season values obtained from previous studies (Table 4.3.2) ranged from 7.0µg/m3 to 22.0µg/m3 with a mean deviation of 14.8±4.14µg/m3 (Table 4.3.2 Figure 4.3.9). The mean concentrations 3 of PM2.5measured in project area is below IFC limit of 25µg/m as shown in Figure 4.3.9 and represent baseline PM2.5 concentration in ambient air of the project area before construction and operation of the proposed project.

4.3.2 Noise Survey Noise measurement was carried out with air quality study in all the sampling stations. Prolonged exposure to noise of value higher than regulatory limits can result in temporary hearing loss (temporary threshold shift) or permanent hearing loss (permanent threshold shift). The FMEnv permissible noise limit for an 8-hour exposure is 90dB (A). The National environmental Standards and Regulatory Agency (NESREA, 2009) has stipulated permissible noise level limit 85 dB(A) from a factory/workshop and a noise equivalent (Leq) limit of 70dB (A) for industrial outside perimeter fence in Nigeria.

More recently, research has focused on noise as an auditory stressor that can produce both direct and indirect health effects (Sheela, 2000). The direct health effect known to be attributable to noise is hearing loss (resulting from damage to the inner hair cells of the organ of corti) with noise exposure higher than 90 decibels. There are several non-auditory physiological effects of noise exposure including a possible increase in cardiovascular disease from elevated blood pressure and physiological reactions involving the cardiovascular

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endocrine system (Talbott, 1995). In addition, community noise has been shown to adversely affect sleep, communication, performance and behavior, reading and memory acquisition, and mental health (Talbott, 1995). Table 4.3.3: Wet and Dry season Baseline Noise Level in Project Area Location Wet season Dry season Noise Levels Noise Levels (dB Noise (dB A) A) X1 Aleto Community 43.9 65.8 X2 IEFCL Flare Area 45.9 54.3 X3 IEFCL NG Receipt facility Area 65.0 54.1 X4 IEFCL Urea bagging Plant 59.4 51.5 X5 IEFCL Weigh Bridge 45.9 56.7 X6 IEFCL Main Gate 52.6 71.7 X7 Akpajo Community 61.8 67.7 Control 1 Agbonchia Njuru (Control 1) 47.3 64.2 Control 2 Rumukrushi Town (Control 1) 46.8 60.9 Range 43.9-65.0 54.1-71.7 Lavg (dB A) 55.5 63.2 Leq (dB A) 58.70 65.66 L1 (dB A) 68.7 74.8 L10 (dB A) 65.2 72.0 L50 (dB A) 51.8 60.7 L90 (dB A) 41.1 51.2 Standard deviation 7.98 7.01 FMEnv limit 90 90 Sources of dry season data: IEPL, (2012 to 2016)

Noise levels measured within the project area in the wet season ranged from 43.9dB (A) to 65.0dB (A) with a mean deviation of 55.5±7.98dB (A), while mean noise levels in the dry season (Table 4.3.3) ranged from 51.5dB (A) to 71.7dB (A) with a mean deviation of 63.2±7.01dB (A) The measured noise levels recorded in the area during field exercise are within FMEnv limit of

90dB (A) on a weighted scale A as shown in Figure 4.3.10. The L1, L10, L50 and L90 values are within limit as shown in Table 4.3.6. These results show baseline noise condition of the proposed project area.

4.3.4 Stack Emission

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Flue/ Stack Gas monitoring was carried out in accordance with the FMEnv approved term of reference and scope of work for the proposed Train2 project in the existing Indorama complex. The sampling was carried using GA-21 Plus gas analyzer from MADUR Electronics. A total of nine readings were taken for each equipment at 10mins intervals. The mean values were calculated and then converted from ppm to mg/Nm3 as presented in the table 4.3.9 below. The result revealed low concentration of priority parameters measured when compared to the FEPA limit, as such do not have any negative influence on the environment.

Table 4.3.4: Summary result of stack emission from existing stack in the facility

Stacks SO2 NO2 CO H2S CH4 VOCs Temp O2 (%) CO2 (%) (mg/N (mg/Nm (mg/Nm3) (mg/N (mg/Nm3) (mg/Nm3) (0C) m3) 3) m3) Polymer 1.25 18.53 3.63 0.00 1.34 1.61 229.20 16.03 2.00 Incinerator Sludge 2.28 17.38 4.25 0.00 0.54 1.47 244.40 13.79 2.55 Incinerator Olefin Furnace A 0.86 22.67 1.00 0.00 0.00 0.00 198.60 2.43 10.41 GT 02 0.57 28.35 0.00 0.00 0.00 0.00 361.50 17.34 2.45 GT 03 0.86 29.58 0.00 0.00 0.00 0.00 364.50 17.16 3.19 Boiler A 1.14 24.68 0.00 0.00 0.00 0.00 203.80 5.33 9.61 Boiler B 1.03 25.95 0.00 0.00 0.00 0.00 202.30 4.59 9.53 Reformer 0.00 71.62 0.00 0.00 0.00 0.00 126.11 4.44 4.88 FMENV LIMIT 30 - 350 - - - 50.00 0.00 - - - mg/Nm3 3000 1000

Stack Ammonia PM Urea Granulator 36.2mg/Nm3 8.7mg/Nm3 IFC Limit 50mg/Nm3 50mg/Nm3

4.4 SOIL QUALITY 4.4.1 Sampling Methodology Soil samples were randomly collected using the vegetation, slope and elevation as the factor determining the point for each sampling. A GPS reading was taken at each point of sampling to establish the coordinates and the elevation. Composite soil samples were collected at two depths: 0-15cm (Topsoil) and 15 – 30cm (Subsoil) with the aid of Dutch stainless steel hand auger (Plate 4.4.1) from Seven (7) sites at different locations within the proposed project area and two control sites outside the project area. A total number of Eighteen (18) soil samples

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IEFCL Train2 Fertilizer EIA Report were collected. The soil samples were collected in duplicate; those for physical and chemical analysis were packed in Ziploc polythene bags, and those for microbial and oil &grease analysis wrapped in aluminum foil. The samples were neatly labeled, preserved and taken to FMEnv accredited laboratory-Earthquest International laboratory Warri, Delta State for analysis. All in- situ observations were recorded in a field notebook. 4.4.2 Morphological properties The soils of the study area is part of the coastal plain sands some times called Ogoni Sands of South Eastern Nigeria. Anderson (1966) had earlier stated that Ogoni soils were composed of sandy deposits originally laid down at or near sea level in Oligocene to Pleistocene times. The soils of the study area are coarse grained, gravelly, locally fine-grained, poorly sorted, subangular to well rounded (Assez,1975). Ojanuga et al (1981) stated that the genesis of these soils have resulted from cycles of soil formation which alternated with cycles of erosion in the mid tertiary to Holocene era in Nigeria. Soil consistency as observed during the field exercise were between wet (slightly sticky and non sticky) and moist (friable), while soil colour were between black (10YR2/1), Dark red (2.5/YR3/6), Brown (10YR5/3) and Strong brown (7.5YR4/6). The topography of the study area were relatively flat with some gentle slope as observsed around station one (SS1- Okulu Aleto).

Soils of the area with the exception of some localized variations are characterized as very good physical features, poor inherent fertility status, low degree of acidity, low cation exchange capacity (FAO,1990) and predominant sandy texture.

4.4.3 Soil Physico-chemical Characteristics The summary of results of the soil physico-chemical analysis is presented in Tables 4.4.1 and 4.4.2 for the topsoil (0 – 15 cm) and subsoil (15 – 30 cm) respectively, while detailed results for all the sample locations are presented in Appendices 4.4.1. The textural classification of the two soil depths within the study area and control site was predominantly fine-grained fairly consolidated Loamy Sand, Sandy Loam and Sandy Clay Loam soil (using the soil particle size matrix), with considerably low clay content. The sand, silt and clay contents of the topsoil

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IEFCL Train2 Fertilizer EIA Report ranged between 64.50 – 77.00%, 5.80 – 1.10% and 13.80 – 27.00% respectively, while the subsoil recorded 58.80 – 72.20% sand, 6.10-7.90% silt and 20.80 – 34.40% clay. The mean values obtained from the control sample locations were not significantly different from that of the project influence zone. Similar textural characteristics have been reported for the study area from previous studies of IEFCL- Train1 EIA 2010. The texture of a soil determines the water absorption/infiltration rate, the water holding capacity and migration of pollutant down the soil strata (Agede 2009). It also determines the amount of soil aeration, ease of tilling, and soil fertility (Udoh 1986). High sand percentage observed on the soil result is indicative of porous nature of the soil, which may encourage easy percolation of nutrients and pollutants to the groundwater table in the event of chemical spillage, while the moderate clay content of the soil is suggestive of greater cohesion, plasticity and aggregation of the soil particles for a better soil structure and possible soil stability especially under high engineering activity.

Other parameters that determine the dynamics of pollutants in soil include bulk density and porosity. The bulk density in particular gives a rough estimation of the aeration and permeability of a soil. The lower the bulk density, the higher the soil permeability to encourage free movement of liquid substance across the soil horizon (Nwachukwu 2016). Bulk density varies with structural conditions of the soil. Therefore, it is related to packing and often used as a measure for soil structure. The results obtained in this study revealed porosity range of 43.80- 53.20% and bulk density 0.15 – 0.28 for topsoil, while the respective values for subsoil ranged from 44.00 – 56.08 % and 0.18 – 0.33 g/cm3, with no significantly different (p>0.05) when compared to the control values. The low soil bulk density result revealed that no form of soil compaction is in progress within and outside the project influence zone (Nwachukwu 2016).

The strength of soil changes with respect to soil water content. Thus, the soil moisture content ranged from 0.24 – 1.15 and 0.26 – 0.51 for topsoil and subsoil respectively. Both the moisture content and bulk density recorded in the cause of this study depict strong soil with respect to compressibility. Brady and Weil, (1999) remarked that soil moisture, plasticity and particle size

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IEFCL Train2 Fertilizer EIA Report of soils determine stability of soils in response to loading forces from traffic, tillage and building foundations. Clay content, nature of clay, nature of exchangeable cations and organic matter content of soils vary, and these influence the plasticity and general activity levels of soils. The soil reaction falls within acidic pH range of 4.70–5.60 (5.22 ± 0.39) for topsoil and 4.30 -6.80 (5.37 ± 1.03) for subsoil indicating that the soil is slightly acidic, which is typical of a Niger Delta soil (Isirimah 1987). pH is often considered in terms of the soil capability and suitability to support plants growth. This is because the value of the free H+ concentration in a soil influences the availability of nutrient elements and biochemical reactions in the soil (Bohn et al., 1984). Agriculturally, soil pH has so far been proven to influence nutrient absorption and plant growth through the availability of plant nutrient and presence of toxic element harmful to plants. Therefore soil pH is like an index parameter to estimate concentration of other parameters in the soil, just like low pH increases heavy metal concentration in the soil (Itanna 1998); pH <6.5 affect the availability of Phosphorus (Brady, 1974). Consequently, the present pH condition of the soil may enhance the solubility and mobility of heavy metals and their subsequent percolation to the groundwater table but may slow down microbial degradation. The optimum pH values for pollutant-degrading microorganisms range from 6.5 to 7.5 (Margesin and Schinner, 2005).

The Organic matter content of the soil ranged from 0.09-0.21 at the topsoil, while the subsoil ranged from 0.08 – 0.16% indicating low organic matter content of both topsoil and subsoil according to FAO (1990) classification, which also reflected in the Total Organic Carbon results recorded during this studied. Spatial variation in the measured TOM values across the sampling stations was not too high with coefficient of variation less than 25%. Soil organic matter contributes to soil aggregation and reduces susceptibility to erosion (Brady and Weil, 1996). As such many important soil properties are dependent on the quality of organic matter present in soil. These properties include the absorption and retention of water, reserves of exchanged bases, the capacity to supply nitrogen, phosphorus and other elements to growing crops, stability of soil structure, adequacy of aeration and pollutants bioavailability (Margesin and

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Schinner, 2005). In fact pollutant concentrations in soil are normalized with the organic matter in conjunction with clay content (DPR, 2002).

Total Nitrogen levels ranged between 0.08 -0.39% and 0.08 – 0.27%for both the top and sub soil respectively indicating that Medium to high soil fertility according to FAO (1990) classification of soil. Soil N of more than 0.15% is considered optimal for most crops (Sobulo and Osiname, 1986). Nitrogen concentrations in soils generally fall sharply with depth, with most of the nitrogen being in the top one meter layer of soils. Over 90%, of the nitrogen in the surface layers (A-horizon, plow-depth zone) of soil is in organic matter (Bremmer, 1965; Stevenson, 1982). Total phosphorus levels in the topsoil and subsoil also fall within low soil fertility classification (FAO, 1990), with a value range between 0.13 – 0.28 for topsoil and 0.14 – 0.32mg/k for subsoil, this can be a result of slight acidic nature of the soil which must have fixed the phosphorus content of the soil (Brady, 1974). Phosphorus in soils is present in the soil solution (plant- available); as labile phosphate precipitates and adsorbed to soil particles, mainly clay minerals (potentially available to plants); as non-labile phosphate in the form of calcium, iron, and aluminum phosphate (not plant-available); in organic form, including P in soil organic matter (released after mineralization); and in living soil biomass. Phosphorus is utilized in the fully oxidized and hydrated form as orthophosphate. Deficiency of phosphorus may limit the growth of plants and the microbial decomposition of pollutants in soil. Phosphorus is likely to be deficient in hydrocarbon-impacted soils and sub-soils.

The exchangeable cations (Ca, Mg, K and Na) are positively charged ions usually absorbed by electrostatic or columbic attraction to soil surface colloids. Plants absorbed it in exchangeable form (Donahue, 1990).The exchangeable cations for the surface soils were as follows: Ca (range, 0.61 – 1.30cmolkg-1); Mg (range, 0.36 – 5.61cmolkg-1); K (range; 0.95 – 4.15cmolkg-1) and Na (range, 4.61 – 22.51cmolkg-1) for topsoil. While, the following values were recorded for the subsurface soils; Ca (range, 0.50 to 1.21); Mg (range, 0.34 – 2.27 cmolkg-1); K (range, 0.80 - 2.90 cmolkg-1) and Na (range 4.46 – 18.06 cmolkg-1) for subsoil. The exchangeable acidity

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ranged between 0.70 – 1.20 cmolkg-1 for topsoil and 0.60 – 1.40 cmolkg-1 for subsoil; cation exchange capacity (CEC) (0.81 – 1.32cmolkg-1) for topsoil and between 0.70 – 1.49cmolkg-1for subsoil, while base saturation ranged between (3.85 – 13.79%) for topsoil and between 2.64 – 13.85% for subsoil) with no significant (p>0.05) mean variation of project zone influence and the control station.

Oil and grease content of the soil ranged from 1.28 to 6.16mg/kg topsoil and 0.92 to 1.52mg/kg subsoil. The oil and grease concentration were more on the topsoil and lower on the subsoil. However the oil and grease content of the soil were generally low indicating no form of oil spillage within the study area, this is further corroborate by the low presence/count of HUB recorded in the cause of this study.

Table 4.4.1: Summary of Physiochemical properties of soil within the project area (0-15cm) PARAMETERS Min Max STD Ave CV % Control 1 Control 2

Sand (%) 64.50 77.00 4.32 69.05 6.25 76.5 66.7

Silt (%) 5.80 10.10 1.70 8.05 21.18 1.3 21.4

Clay (%) 13.80 27.00 4.75 22.90 20.75 22.2 11.9

Porosity (% Pore space) 43.80 53.20 3.38 50.07 6.75 42.80 50.90

Permeability (k-4cm/hr) 1.70 2.10 0.22 1.90 11.53 1.9 1.6

Bulk Density (g/cm) 0.15 0.28 0.05 0.23 20.39 0.22 0.20

Moisture Content (%) 0.24 1.15 0.31 0.60 51.60 0.72 0.42 pH 4.70 5.60 0.39 5.22 7.51 4.80 5.30

Electrical Conductivity (us/cm) 48.20 172.20 42.07 108.42 38.81 124.60 39.40

Phosphorous (%) 0.13 0.28 0.05 0.18 28.59 0.14 0.12

Total Nitrogen (%) 0.08 0.39 0.11 0.19 58.01 0.126 0.163

CEC (cmol/kg) 0.81 1.32 0.18 1.04 17.76 1.21 1.04

2- SO4 (mg/kg) 2.70 7.25 1.67 4.47 37.34 8.661 2.757

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NO3 - N (mg/kg) 0.05 0.18 0.06 0.12 48.78 0.065 0.048

NH4 - N (mg/kg) 0.16 0.52 0.16 0.37 42.38 0.178 0.189

O & G (mg/kg) 1.28 6.16 1.93 2.22 86.93 2.31 0.68

TOC (%) 0.04 0.13 0.03 0.10 33.68 0.25 0.26

OM (%) 0.09 0.21 0.04 0.17 24.76 0.39 0.33

Exc. Acidity (meq/100g) 0.70 1.20 0.19 0.95 19.69 1.1 1

Base Saturation (%) 3.85 13.79 3.90 9.07 42.99 9.40 3.44

CATIONS

Ca (cmolkg-1) 0.63 1.30 0.25 0.90 28.27 0.859 0.719

Mg (cmolkg-1) 0.36 3.61 1.36 1.97 68.89 1.631 0.120

Na (cmolkg-1) 4.61 22.51 6.76 14.74 45.88 21.264 6.314

K (cmolkg-1) 0.95 4.15 1.37 2.83 48.27 1.501 1.400

Field survey 2017

Table 4.4.2: Summary of Physiochemical properties of soil within the project area (15-30cm) PARAMETERS Min Max STD Ave CV % Control 1 Control 2

Sand (%) 58.80 72.20 5.43 65.15 8.34 71.1 75.9

Silt (%) 6.10 7.90 0.63 7.07 8.93 5.4 5.7

Clay (%) 20.80 34.40 5.18 27.78 18.63 23.5 18.4

Porosity (% Pore space) 44.00 56.08 4.35 50.70 8.58 52.30 57.40

Permeability (k-4cm/hr) 1.60 2.00 0.15 1.82 8.10 2.0 1.9

Bulk Density (g/cm) 0.18 0.33 0.07 0.25 27.08 0.28 0.26

Moisture Content (%) 0.26 0.51 0.09 0.41 22.31 0.16 0.15 pH 4.30 6.80 1.03 5.37 19.14 5.50 5.50

Electrical Conductivity (us/cm) 41.10 121.70 39.44 78.47 50.26 38.30 34.50

Phosphorous (%) 0.14 0.32 0.07 0.21 33.37 0.22 0.19

Total Nitrogen (%) 0.08 0.27 0.07 0.17 38.37 0.068 0.120

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CEC (cmol/kg) 0.70 1.49 0.33 1.03 31.85 1.04 0.93

2- SO4 (mg/kg) 2.92 7.31 1.51 5.66 26.72 1.648 2.432

NO3 - N (mg/kg) 0.04 0.22 0.06 0.10 64.98 0.056 0.087

NH4 - N (mg/kg) 0.12 0.47 0.13 0.33 38.66 0.176 0.268

O & G (mg/kg) 0.92 1.52 0.33 1.14 28.99 <0.01 <0.01

TOC (%) 0.03 0.09 0.02 0.06 36.51 0.04 0.07

OM (%) 0.08 0.16 0.03 0.12 26.95 0.07 0.12

Exc. Acidity (meq/100g) 0.60 1.40 0.34 0.97 35.03 1 0.9

Base Saturation (%) 2.64 13.85 4.67 7.14 65.43 3.39 2.88

CATIONS

Ca (cmolkg-1) 0.50 1.21 0.25 0.72 35.44 0.881 0.530

Mg (cmolkg-1) 0.34 2.27 0.76 1.13 66.77 0.592 0.167

Na (cmolkg-1) 4.46 18.06 6.56 11.13 58.97 5.063 4.657

K (cmolkg-1) 0.80 2.90 0.85 1.63 52.25 1.451 0.933

Field survey 2017

4.4.4 Soil microbiology Soil represents a very favorable habitat for microorganisms and is inhabited by a wide range of microorganisms, including bacteria, fungi, algae, viruses and protozoa. Microorganisms are found in large numbers in the soil (usually between one and ten million microorganisms are present per gram of soil) with bacteria and fungi being the most prevalent. However the availability of nutrients is often limiting for microbial growth in soil and may increase soil fertility and plant growth. Consequently, an investigation to determine existence of heterotrophic as well as hydrocarbon Utilizing bacteria and fungi in the study area was carried out and presented in (Table 4.4.3.). The total population of total heterotrophic bacteria (THB) ranged from 0.52x104 to 4.50x104(cfu/g) for topsoil and 1.50x104– 3.95x104(cfu/g) for subsoil; total heterotrophic fungi (THF) ranged from 0.15x104 – 1.59x104(cfu/g) for topsoil and 0.45x104– 2.00x104(cfu/g) for

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subsoil. The population of total hydrocarbon utilizing bacteria (THUB) ranged from 0.25x104– 1.96x104(cfu/g) for topsoil and 0.37x104– 1.99x104(cfu/g) for subsoil, and the total hydrocarbon utilizing fungi (THUF) ranged from 0.64x104 – 3.00x104(cfu/g) for topsoil and 0.22x104– 3.50x104(cfu/g) for subsoil. Comparatively, the hydrocarbon utilizers were the least in population. Therefore, it can be said that there is no significant hydrocarbon pollution around the study area to encourage the significant presence of this bacteria, this is further justified by low concentration of oil and grease content in the soil samples.

Table 4.4.3: Summary of soil microbes within the project area PARAMETERS Min Max STD Ave CV % Control 1 Control 2 Topsoil THB (cfu/g X 104) 0.52 4.50 1.47 2.64 55.77 1.00 1.61 THF (cfu/g X 104) 0.15 1.59 0.55 0.86 64.25 0.45 0.23 HUB (cfu/g X 104) 0.25 1.96 0.63 0.74 84.35 0.20 1.45 HUF (cfu/g X 104) 0.64 3.00 0.84 1.50 55.96 2.00 0.38 Subsoil THB (cfu/g X 104) 1.50 3.95 1.09 2.65 41.29 2.03 0.85 THF (cfu/g X 104) 0.45 2.00 0.56 0.99 55.87 0.94 0.12 HUB (cfu/g X 104) 0.37 1.99 0.60 1.11 53.75 0.27 NIL HUF (cfu/g X 104) 0.22 3.50 1.29 1.62 79.66 1.21 0.5 Field survey 2017 4.4.5 Soil Fauna The soil macro-fauna identified through visual observation in the study area include various arthropods (Myricarid striata, Dorylus fimbriatus, Glomens marginata), Annelids (Earthworms) and Nematodes (Acanthamoeba polyphaga, Acrobeloides sp, Porcellia scraber). These organisms are primary consumers; decomposers, mixers and utilizers of energy stored in plants and plant residues, and contribute to the recycling of nutrients. They also help in soil particle aggregation to encourage soil stability. Others are secondary consumers such as centipedes and spiders. These animals consume smaller sized animals and they, also may serve as food for organisms occupying higher levels of the food chain. Soil fauna are notable and are critical in the biological turnover and nutrients release of plant residues by fragmenting the plant residues, resulting in enhanced microorganism activities and

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grazing of microflora by fauna. Anderson and Fletcher (1988) noted a symbiotic interaction between earthworm and microorganism in the breakdown and fragmentation of organic matter.

4.4.6 Heavy metals Heavy metals analysis in the soil samples revealed Iron (Fe) having the highest concentration (Mean 6847.25mg/kg topsoil and 6685.20mg/kg subsoil), while mercury (Hg) and Vanadium (v) recorded the lowest concentration <0.05mg/kg, Lead concentration ranged from 38.14 to 51.16 topsoil and 31.03 to 48.74mg/kg subsoil. Similar values were recorded at the control stations. High concentration of iron in soil is common within the Niger Delta environment Aiyesanmi, 2005). Agriculturally, Iron concentration above 360 mg/kg is considered high and can adversely affect crop yield (FAO, 1990).

Table 4.4.4 Summary of heavy metal composition in soil within the project area

PARAMETERS Min Max STD Ave CV % Control 1 Control 2

Topsoil V (mg/kg) <0.05 <0.05 <0.05 <0.05 <0.05 <0.05 <0.05 Ni (mg/kg) 7.81 17.32 3.19 13.27 24.00 13.569 13.377 Fe (mg/kg) 5931.95 8592.83 989.02 6847.25 14.44 3709.220 4468.470 Pb (mg/kg) 38.14 51.16 4.84 43.43 11.15 38.920 38.170 Cu (mg/kg) 7.06 11.31 1.52 8.84 17.23 5.906 5.806 Zn (mg/kg) 60.66 80.38 7.63 69.67 10.95 72.275 70.973 Cd (mg/kg) 5.31 8.90 1.37 7.88 17.37 8.925 2.675

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Cr (mg/kg) 0.40 1.25 0.35 0.78 45.42 0.119 0.619 Hg (mg/kg) <0.05 <0.05 <0.05 <0.05 <0.05 <0.05 <0.05 Subsoil V (mg/kg) <0.05 <0.05 0.00 0.00 0.00 <0.05 <0.05 Ni (mg/kg) 10.92 17.27 2.07 14.01 14.80 17.283 15.621 Fe (mg/kg) 4003.32 8401.76 1583.27 6685.20 23.68 2915.960 2023.670 Pb (mg/kg) 31.03 48.74 7.70 41.31 18.65 40.590 38.280 Cu (mg/kg) 5.16 10.41 1.71 7.89 21.65 3.954 5.005 Zn (mg/kg) 52.96 78.58 9.23 64.02 14.43 52.254 62.765 Cd (mg/kg) 6.28 8.60 0.92 8.15 11.30 4.838 2.825 Cr (mg/kg) 0.12 3.78 1.32 1.41 93.51 0.189 0.561 Hg (mg/kg) <0.05 <0.05 <0.05 <0.05 <0.05 <0.05 <0.05 Field survey 2017

4.4.7 Land use Land use within the study area is largely affected by large extent of human activities such as industrilisation, municipal and agricultural activities. High industrialization, which is at its peak within the area has resulted to visible reduction in agricutural activity of the study area. The notable landuse within the study area included Indorama complex (which is playing host to the proposed IEFCL-Train2 fertilizer), NNPC estate adjcent to Indorama complex, Onura shrine, Port Harcourt Refinery, fuel stations and road infrastucture network. Comparatively, Port Harcourt Refinery, Indorama complex and NNPC Estate occupies very prominent space in the land use of the study area.

4.5 Vegetation and Wildlife The study covered the ecology of the host communities directly neighboring the project which are Akpajo, Agbonchia and Aleto. The area lies within the riparian lowland forest with a two layer canopy characteristics .Furthermore, the study area is mainly low lying and thus, experiences seasonal flooding. In the same vein, the terrain is relatively flat. The soils in the region are mainly sandy-loam, clayey-loam and clayey soils. Also the soils of the area are poorly

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drained as the soils are constantly wet and moist. The area has an average rainfall of about 2000mm-3000mm. temperature of about 280c and 75% relative humidity

4.5.1 Vegetation 4.5.1.2 TREE/SHRUB SPECIES COMPOSITION Within the study area, a total of thirteen tree/ shrub species occurred and out of which no specie (tree/shrub) was abundant but rather, one specie was found to be common and that specie was Elaeis guinensis. In the same vein, four species were occasional and they include; Anthonota macrophylla, Alchornea cordifolia, Alstonia boonei and Harungana madascariensis. However, eight species were found to be rare and they are; Ficus exasperate, Psidium guajava, Anthocleista vogelii, Musanga cecropioides, Anacardium occidentalis, Bambusa vulgaris, Baphia nitida and Persea Americana.

Table 4.5.1: Tree/Shrub Species Composition s/n Tree shrub composion Common name Family A C O R 1 Ficus exasperate Forest sand paper Moraceae X 2 Elaeis guinensis Oil palm Arecaceae x 3 Psidium guajava guava Mytraceae X 4 Anthonota macrophylla African rose wood Mimosaceae x 5 Anthocleista vogelii English cabbage tree Potaliceae X 6 Musanga cecropioides Umbrella tree Urticaceae X 7 Alchornea cordifolia Christmas bush Apocynaceae x 8 Alstonia boonei African nut tree Apocynaceae x 9 Anarcadium occidentalis Cashew tree Anacardiaceae X 10 Harungana madascariensis Dragon blood tree Hypericaceae x 11 Bambusa vulgaris Bamboo Bambusae X 12 Baphia nitida Cam wood Fabaceae X 13 Persea Americana Avocado Lauraceae X

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Abundant Common Ocassional Rare

Figure 4.5.1 Tree/Shrub Species Composition in the Study Area

Twelve families were seen to occur within the thirteen tree/shrub species. From the occurrence, it was observed that a total of eleven families based on their ecological status were found to be rare and they include; Moraceae, Arecaceae, Mytraceae, Mimosaceae, Potaliceae, Urticaceae, Anacardiaceae, Hypericaceae, Bambuseae, Fabaceae and Lauraceae while Apocynaceae was the only occasionally occurring family.

TABLE 4.5.2: TREE/SHRUB FAMILY COMPOSITION s/n Family Frequency A C O R 1 Moraceae 1 X 2 Arecaceae 1 X 3 Mytraceae 1 X 4 Mimosaceae 1 X 5 Potaliceae 1 X 6 Urticaceae 1 X 7 Apocynaceae 2 x 8 Anacardiaceae 1 X 9 Hypericaceae 1 X 10 Bambusae 1 X 11 Fabaceae 1 X

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12 Lauraceae 1 X TOTAL 13 Field survey 2017

Abundant Common Ocassional Rare

FIG. 4.5.2 Tree/shrub Species Family Composition in the Study Area

4.5.1.2 HERBACEOUS SPECIES COMPOSITION A total of eighteen (18) herbaceous species were found to occur within the study area and from the occurrences, it was observed that Panicum maximum was the only abundant occurring family while Ipomoea involucrate was the only common family. Occasionally speaking, six herbaceous species were found to be in that range and such species include; chromoleana odorata, pennisetum purpureum, cyperus spp, costus afer, kyllinga erecta and sida acuta. Moreover, nine (9) species were rare and they were; Aspilia Africana, Elusine indica, Spermacoce venticullata, Mimosa pudica, Calopogonium mucunioides, Senna occidentalis, Amaranthus spinosus, Imperata cylindrical and Emilia sonchifolia

TABLE 4.5.3: HERBACEOUS SPECIES COMPOSITION S/N Herbaceous species Common name Family A C O R 1 Panicum maximum Guinea grass Poaceae x 2 Aspilia africana Haemorrhage plant Asteraceae X 3 Elusine indica Wire grass Poaceae X

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4 Centrosema pubescens Butterfly pea Fabaceae x 5 Spermacoce venticullata Shrubby false Rubiaceae X buttonweed 6 Mimosa pudiica Shame weed Fabaceae X 7 Chromoleana odorata Siam weed Asteraceae x 8 Calopogonium Wild groundnut Fabaceae X mucunoides 9 Senna occidentalis Coffee weed Fabaceae X 10 Amaranthus spinosus Spiny pigweed Amaranthaceae X 11 Pennisetum purpureum Elephant grass Poaceae x 12 Imperata cylindrical Cogon grass Poaceae X 13 Cyperus spp Nutsedges Cyperaceae x 14 Emilia sonchifolia Tassel flower Asteraceae X 15 Costus afer Spiral ginger Costaceae x 16 Ipomoea involucrate Morning glory Convolvulaceae x 17 Kyllinga erecta Spikesedges Cyperaceae x 18 Sida acuta Broomweed Malvaceae x Field survey 2017

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Herbaceous species composition in IEPCL 9 8 7 6 5 4 Rare 3 Abundance 2 Series1 1 0 Series2 Series3

Occasional Common

FIG.4.5.3 Herbaceous Species Composition in the Study Area

4.5.1.4 HERBACEOUS FAMILY COMPOSITION In consideration of the herbaceous family composition within the study area, it was observed that a total of nine families occurred within the eighteen (18) herbaceous species. Further, two families namely Poaceae and Fabaceae were in abundance while Asteraceae was the only commonly occurring family. In the same vein, cyperaceae was found to be the only occasionally occurring family. However, five species were found to be rare and they include Rubiaceae, Amaranthaceae, Costaceae, Convolvulaceae and Malvaceae

TABLE 4.5.4: HERBACEOUS FAMILY s/n Family Freq A C O R

1 Poaceae 4 x 2 Asteraceae 3 x 3 Fabaceae 4 x

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4 Rubiaceae 1 X 5 Amaranthaceae 1 X 6 Cyperaceae 2 x 7 Costaceae 1 X 8 Convolvulaceae 1 X 9 Malvaceae 1 X TOTAL 17 Field survey 2017

5

0

Figure 4.5.4 Herbaceous Family Species Composition in the Study Area 4.5.2 Wild Life Species Composition In The Area A total of twenty-one (21) wildlife species occurred within the study area and it was observed that no wildlife species was found to be abundant but however, three wildlife species were common namely Rattus rattus, Streptopelia senegalensis and Corvus albus. Occasionally, eleven (11) wildlife species were found in this range and they include Cricetomys emini, Lemniscomys striatus, Dendroaspis viridis, Pycinonothus barbatus, Nectarinia chloropygia, Anthreptes gabonicus, Nectarinia fuliginosa, Streptopelia semitorqota, Milvus migrans, Ploceus cucullatus and Apus affinus. Nevertheless, seven (7) wildlife species were found to be rare and such species include; Thryonomys swinderianus, Varanus niloticus, Python sabae, Agama agama, Vidua macroura, Ploceus nigerimus and Ploceus inelanocephala.

Table 4.5 5: Wild Life Species in the study area

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IEFCL Train2 Fertilizer EIA Report s/n Common names Scientific names A C O R 1 Greater cane rat Thryonomys swinderiamus X 2 Emins giant rat Cricetomys emini X 3 Black house rat Rattus rattus x 4 Spotted grass mouse Lemniscomys striatus X 5 Nile monitor lizard Varanus niloticus X 6 Rock python Python sabae X 7 Agama lizard Agama agama X 8 Green mamba Dendroaspis viridis X 9 Common garden bulbul Pycinonothus barbatus X 10 Pintailed whydah Vidua macroura X 11 Olive bellied sunbird Nectarinia chloropygia X 12 Mouse brown sunbird Anthreptes gabonicus X 13 Carmelite sumbird Nectarinia fuliginosa X 14 Red eye dove Streptopelia semitorqota X 15 Laughing dove Streptopelia senegalensis x 16 Black kite Milvus nigrams X 17 Pied crow Corvus albus x 18 Village weaver Ploceus cucullatus X 19 Viellot’s black weaver Ploceus nigerimus x 20 Black-headed weaver Ploceus inelanocephala x 21 Little African swift Apus affinis X Field survey 2017

Abundant Common Occasional Rare

FIG.4.5.5 Wildlife Species Composition in the Study Area

4.5.2.1 PLANT DISEASES SYMPTOMS AND ISOLATED PATHOGENS

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In the study area, plant disease symptoms and isolated pathogens of some plants were observed and asserted. Tissue analysis from the herbarium, showed that four plants species were sampled namely Chromoleana odorata, Costus afer,Anthocleista vogelii and Calapogonium mucunoides had one form of disease symptoms and so on. From the foregoing, it was observed Chromoleana odorata had common symptoms like leaf spot, mold and blight and necrotic lesions which were caused by Botrylis linerea, while Costus afer had dead streaks, black colorations and wilting of leafs which was believed to be caused by Oedecephallum spp. Thielaviopsis mosaic/ Curvuleria Spp was the pathogen that caused by yellow molting and wilting of leaves on Anthocleista vogelii and Calapogonium mucunoides. Summarily, four isolated pathogens were the major causes of disease in the study area. Also, in spite of the few observed disease and symptoms on plants species this was not a serious issue as the disease range and impacts were minor. Therefore, the general plant health and conditions was in shape. Hence, the vegetation of the area was healthy.

Table 4.5.6: PLANT DISEASES SYMPTOMS AND ISOLATED PATHOGEN S/N PLANT SPECIES DISEASE SYMPTOMS ISOLATED PATHOGENS 1 Chromoleana odorata Leaf spot, mold and blight, Botrylis linereae necrotic lesions 2 Costus afer Dead streaks. Black colouration Oedecephallum spp and wilting 3 Anthocleista vogelii and Soty molds, yellow wilting and Thieleviopsis mosaic/ Calapogonium mucunoides molting Curvuleria Spp Field survey 2017 4.6. Hydrogeology Geologically, the site is underlain by the coastal plain sands, which in this area is overlain by firm – stiff clay/sandy clay sediments belonging to the pleistocenic formation. The general geology of the area essentially reflects the influence of movements of rivers in the Niger Delta and their search for lines of flow to the sea with consequent deposition of transported sediments. In broad terms, the area may be considered flat. The site is accessible from East-West Road – Onne – (from Eleme Junction to Alsea-Eleme Community) via Eleme refinery axis.

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Environmental/Geophysical and Geotechnical/Groundwater data of the underlying soils are needed for the study of the subsurface conditions. Consequently, Environmental, Geophysical survey (VES), were performed at the existing environmental Geotechnical boreholes/monitoring boreholes perimeter to conduct a limited subsoil investigation at the site.

4.6.1 Geomorphology The geomorphology of the study area Indorama Complex and Alesa Eleme corresponds with that of Niger Delta. The area forms part of Niger Delta, which extends from the Forcados in the West to Calabar River in the East and covers a distance of about 350km. The Delta has a narrow coastal strip varying in width from a few meters to about 16m, it makes up more than half of the Southern Nigeria basin, which includes all the sedimentary sequences, bounded by Benin hinge line in the West and the Calabar hinge line on the East. The Delta is tropical one, being composed mainly of fine grained deltaic sediments. The area is tectonically stable and is situated in the equatorial rain forest belt. The Niger Delta is characterized into five (5) major intergradational geomorphologic units (Allen, 1965; short and stumble, 1975, and Wigwe, 1975). These units occur from land to sea as.  Dry flatland and plain  Dry deltaic plain with rare fresh water swamps  Extensive fresh water swamps and meander belts  Saltwater mangrove swamps, estuaries, creeks and lagoons  Abandoned and active coastal Islands and beaches The study area falls under dry flat land plain. There is dense rain forest vegetation in area. 4.6.2 Geology 4.6.2.1 Geology (General Geology of Niger Delta) The geology of the Niger Delta has been described by various authors including Allen, 1965 and short and stumble, 1975. The formation of the Niger Delta began in the early Palaeocene times and was as a result of the buildup of fine – grained sediment eroded and transported by the River Niger and its tributaries. The Niger Delta is composed of three subsurface

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lithostratigraphic units (Akata, Agbada and Benin formations overlain by various deposits of Quaternary Age. The Benin formation (2100m thick) is the most prolific aquifer in the region and constitutes over ninety percent (90%) massive, porous sands with localized clay/shale interbeds. The quaternary deposits (40 – 150m thick) generally consist of rapidly alternating sequences of sand and silt/clay, with the latter becoming increasing more prominent seawards.

The Agbada formation underlies the Benin formation and was deposited under transitional environment, with an almost equicom positional makeup of sands and shales. However increasing clay may occur with depth. Underlying the Agbada formation is the Akata formation, which was deposited, in marine environment. It consists of marine clays, silts and shales with occasional turbidite sand lenses. The formation is rich in organic matter and is the source rock of oil in the Niger Delta. It has a relative thickness of 20,000ft (5882m).

Table 4.6.1: Geologic Unit of the Niger Delta (Allen, 1965) Geologic Units Lithology Age Alluvium (general) Gravel, sand, clay, silt Quaternary Fresh water back swamp meander Sand, clay, some silt, gravel Quaternary belt Mangrove and salt water/back Medium fine sands clay & some silt Quaternary swamps Active & abandoned beach ridges Sand, clay and some silt Quaternary Sombreiro-Warri Deltaic Plain Sand, clay and some silt Quaternary Benin Formation (coastal plain sand) Coarse to medium sand with Miocene subordinate silt & clay Agbada Formation Mixture of sand, clay & silt Eocene Akata Formation Clay Palaeocene

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Figure 4.6.1: geologic characteristics of the study area

Local geology The geology of the catchment area consists of alluvia and fluvia sediment deposits of peat, clay and sands within the depth probed.

Terrain The terrain within the local study area originally consists of mud flats with slight slope and swamps with dry sand ridges (sand fill) on which the facilities and settlements are found. A number of creeks and streams that empty into Okulu Stream that empties into Okirika Channel which empties into Bonny River also exist. 4.6.3 Hydrology The hydrologic system in the catchment area can be conceptualized by series of flat and dipping topography towards Okulu Stream flow direction and other valleys (wetland).

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To assess the hydrology of ground water in area three (3) existing boreholes were considered borehole 1-3 in triangular array. This is to capture ground water flow direction and the heterogeneity of the subsurface a cross the area. The position and the slope of the water table (potentio metric surface in confined aquifer) is determined by measuring the position of the water level in wells from a fixed measuring point. The direction of slope of the water table is also important because it indicates the direction of ground water flow. However, if the depth to water in a non-flowing well (hw) is subtracted from the altitude of the measuring point (z) the result is the total head (ht) Z-hw=ht Using the above relation to determine the slope of water table i.e. direction of ground water movement. The respective total head (ht) of the borehole wells are determined relative to a common datum plane. In summary, the direction of ground water movement and the hydraulic gradient can be determined if the following data are available for at least 3 wells located in any triangular arrangement.  Relative geographical position of the wells  Distance between the wells  Total head at each well The ground water flow direction was determined following the graphical constructional approach of R.C Health (U.S Geological Survey Water supply Paper 2220). The triangular plot indicating the direction(s) of ground water flow is presented below while the respective parameters of boreholes are stated below. Borehole 1 Altitude, (z2=20.5m (asl) Depth water level, (hw) 6.5m Total head, (ht)=14m (asl)

Borehole 2 Altitude, Z=18m (asl) Depth to water level, hw= 6.1m Total head (ht) =11.9 (asl) Borehole 3

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Altitude z=24.6m (asl) Depth to water level, hw=7.6m Total head (ht)=17m (asl)

As indicated in fig 4.6.2 below (flow direction chart) the general flow direction in the vicinity of the catchment area is to the South-East.

This is supported by the regional factors such as SSE trending pattern of Affluent River, topographic conditions as well as buried stream channels (surface outflow) in the study area.

Precipitation infiltrates the over burden vadose zone (clay and sand), surface impoundments before recharging the sand and gravel shallow aquifer and very slowly discharges naturally into the stream/rivers. Also within the study area water leaves the shallow aquifer through ground water withdrawal by pumping from the existing water boreholes supplies and evapo- transpiration by capillarity rise, surface run-off from the built-up areas and plant areas into the drainage. There are good network open drainage system all over with man-hol in places where the run-off entered and empties into the stream water body in the area. Following Darcy’s law (velocity is proportional to both the hydraulic conductivity of the formation and the hydraulic gradient) more of in the horizontal flow. Also vertical flow of ground water and contaminants by gravity causes the leakage from the aquifer into adjacent strata.

Also, the overland out flow from surface water impoundment (dump pits, well pit etc.) can contribute to the distribution of chemicals in the overburden vadose zone and farm lands in the area.

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BH3 Swl7.6m

Swl 6.1m BH2 BH1 Swl6.5m

Figure 4.6.2 Ground water flow direction at Urea, Train 2 proposed site in Indorama Complex, Rivers State

4.6.4 Groundwater quality of Boreholes The physiochemical properties of ground water are presented in Table 4.6.2. The result reveals that the ground water quality is slightly acidic to moderately alkaline which is typical to Niger Delta groundwater quality. Nutrient content result were very low across all stations indicating that the ground water is not under any form of organic stress, this is further justified by the low concentration of BOD result. Heavy metal were almost <0.001 except for iron with a maximum concentration below <7.5mg/l. Bacterial count were low to influence the ground water of the area. The seasonal variations of both seasons were very marginal as such will not influence the influent process water quality to the plant.

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Table 4.6.2: Physiochemical properties of ground water within Indorama complex and control stations PARAMETER Wet season Dry season

BH1 BH2 BHC BH1 BH2 BHC

IEPL Flare IEPL Water Akpajo IEPL Flare IEPL Water Akpajo Area treatment Area treatment plant plant pH 7.31 6.92 6.61 7.10 6.36 6.65

Temperature 36.4 31.5 27.3 29.9 30.1 34.3

Color Clear Clear Clear Clear Clear Clear

Dissolved Oxygen 1.28 1.29 2.43 2.10 2.20 3.3

Turbidity (NTU) 2.8 2.2 3.28 2.5 1.2 1.5

Conductivity (µs/cm) 199.4 439 393 20.00 21.40 24.0

Total Dissolved Solids (mg/l) 133 219 195 10.00 10.80 12.00

Total Suspended Solids (mg/l) 9.00 21.0 26.0 10.70 8.60 9.40

Total Hardness (mg/l) 18.0 58.0 93.0 12.60 10.50 16.40

Biological Oxygen Demand(mg/l) 0.153 0.835 1.986 2.02 2.00 2.01

Chemical Oxygen Demand (mg/l) 0.229 1.252 2.979 18.20 14.30 18.60

- Nitrate (NO3 ) (mg/l) 2.40 1.80 1.60 0.032 <0.001 0.001

2- Sulphate (SO4 )(mg/l) 36.0 60.0 13.0 19.08 9.08 12.76 Phosphate P043- (mg/l) 0.12 1.09 0.24 <0.001 <0.001 <0.001

Oil and Grease (mg/l) <0.001 <0.001 <0.001 <0.001 <0.001 <0.001

Mercury Hg (mg/l) <0.001 <0.001 <0.001 <0.001 <0.001 <0.001

Copper Cu (mg/l) 0.025 0.091 0.085 <0.001 <0.001 <0.001

Lead Pb (mg/l) <0.001 0.461 <0.001 <0.001 <0.001 <0.001

Zinc Zn (mg/l) 0.071 0.217 0.120 <0.001 <0.001 <0.001

Iron Fe (mg/l) 3.337 6.816 7.096 0.311 0.321 0.308

Cadmium Cd (mg/l) <0.001 <0.001 <0.001 <0.001 <0.001 <0.001

Nickel Ni (mg/l) <0.001 0.061 <0.001 <0.001 <0.001 <0.001

Arsenic (As) (mg/l) <0.001 <0.001 <0.001 <0.001 <0.001 <0.001

Chromium Cr (mg/l) <0.001 <0.001 <0.001 <0.001 <0.001 0.0001

THB (cfu/ml) 1.2x103 1.0x103 2.4x103 2.3x103 1.3x103 1.8x103

HUB (cfu/ml) <0.01 <0.01 <0.01 <0.01 <0.01 <0.01

THF (cfu/ml) 1.4x102 4.1x102 1.08x102 1.7x102 3.2x102 1.1x102

HUF (cfu/ml) <0.01 <0.01 <0.01 <0.01 <0.01 <0.01

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Total coliform (MPN/100 meg) <3.00 <3.00 21.0 4.00 6.00 19.0 Source: Fieldwork 2017 (wet) and 2012 (dry)

4.6.5 Water Budget

Figure: 4.6.3 Rainfall and concurrent evaporation at Indorama Complex Port Harcourt area

The components of water budget equation: Precipitation = Evaporation + Infiltration + Runoff + differential Storage Were analyzed for the proposed urea IEFCL-Train2 Project.

Infiltration was assessed using a simplified version of Darcy’s law. In this model the ponded

water is assumed to be equal to h0 and the head of dry soil that exists below the depth of the wetting front soil suction head is assumed to be equal to − ψ − L.

F = k ( ho - ( - ψ– L)) L Where

h0 is the depth of ponded water above the ground surface; K is the hydraulic conductivity; L is the total depth of subsurface ground in question.

In summary, all of these equations should provide a relatively accurate assessment of the infiltration characteristics of the soil in question

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The water budget implications for the soils were evaluated in relation to the geological formations. Results show that there is very reasonable infiltration and that 60% of total rainfall is translated into runoff.

4.6.5 Geophysical investigation Resistivity was measured by passing a current of known value into the ground by means of two electrodes (C1, C2) and measuring potential difference between two intermediate points in the ground using another two electrodes (P1, P2). The ground whose mean resistivity is measured is that comprised between the voltage electrodes (P1, P2 ) up to a depth (ID) equal to about 1/3 of the distance between C1 and C2 (total electrode spread) and a width equal to about 2/3 of the distance C1 and C2.. As the electrode spread (C1, C2) increases, depth of the probe increases, thereby, giving a vertical electrical sounding. VES also referred to as electrical drilling. The potential – drop – ratio method is a variation on this procedure used for determining resistivity.

All resistivity techniques in general use require the measurement of apparent resistivity ρa, which is obtained from the electrode configuration.

2 2 ρa = π.R.a (b/a + b / a ) Where R = resistance value read on the resistivity meter (Ω) a = distance between both inner electrodes (m) b = distance between inner and outer electrodes (m)

ρa = avearage resistivity (Ωm) of an equivalent soil layer which is equal to 75% of the distance between the inner and outer electrodes (0.756)

4.6.5.1 Instrumentation The measuring field equipment used include: SR-2 Soil Resistivity Meter with a liquid crystal digital readout containing three main units; all housed in a single casing; the transmitter, the receiver and the micro-processor. The electrically isolated transmitter sends out well-defined and regulated signal currents. The receiver discriminates wise and measure voltage correlated with transmitted signal current (resistivity surveying mode), the microprocessor monitors and controls operations and calculates ground resistance.

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A pair of current electrodes and pair of potential electrodes all made of stainless steel. Rolls of copper cables with connecting cables, plugs and clips.

4.6.5.2 Data Processing Raw field data was transferred to computer on completion of each day and the data was checked to verify accuracy and that the equipments was fully functional and to identify and measurement which may require immediate resurvey. Data was finally analyzed by mathematical methods using appropriate constants and are presented in a tabular form by an appropriate computer programme. The VES data are then presented as sounding curves, which are obtained by plotting graph of apparent resistivity versus depth on the logarithmic graph sheets.

4.6.5.3 Results The results are displayed in the table and graphics is presented in appendix 4.6.1. The computer-modeled curve (Apparent resistivity graphics and sections) is generated from the field data displayed on the table. The geo-electric model summarizes the probable subsurface geology and information on subsurface condition in the survey site.

As resistivity is a fundamental electrical property of rock material closely related to their lithology, thus the determination of the subsurface distribution of resistivity from measurements on the surface can yield useful information on the structure or composition of buried formation. From the result of the 3 geo-electric resistivity measurement certain deductions could be made:

VES 1. The area could be characterized with 3 major geo-electric resistivity zones within a shallow subsurface sounded depth of 30m. The upper subsurface geo-electric zone; 211-2760m, thickness about 5.0m, with Lateritic, Silty clay material. Middle geo-electric zone 500-10000m,

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VES 2. The area could be characterized with 3 major geo-electric resistivity zones within a shallow subsurface sounded depth of 30m. The upper subsurface geo-electric zone; 10000m, thickness about 5.0m, with lateritic silty sand material. Middle geo-electric zone; 6000 – 8000m, thickness about 21.0m, with lateritic sand material. Lower geo-electric zone; 900 – 10000m, with sand – silty sand material.

VES 3. The area could be characterized with 3 major geo-electric resistivity zones within a shallow subsurface sounded depth of 30m. The upper subsurface geo-electric zone; 10000m, thickness about 3.0m, with lateritic silty clay material. Middle geo-electric zone; 300 – 8000m, thickness about 23.0m, with lateritic sand material. Lower geo-electric zone; 900 – 12000m, with sand – gravel/sand material.

VES 1 &3.First and second layers are made up of impervious unit with low porosity and poor permeability while the third layers are made of aquifer layers of high porosity and permeability. The ground water movement is most viable in third layer.

In VES 2 first – third layers ranged from sand to silty sand layers with appreciable porosity and permeability thus must of the infiltration that reaches the ground water discharge to the surface streams/ creek thus enhancing soil flush. Any pollutant can percolate down through the silty soil, then moves rapidly as interflow to the estuarine system. This is a peculiar case with the coastal drainage of unconsolidated top sediment (U.S EPA, 1995). Also VES 1-3 resistivity values, there is one indication of any anomaly as values above 90000Ωm that depicts faults, crack, loose sand or sink holes and fractures etc. are not witnessed.

Table 4.6.1 Summary of geo-electric model in VES 1-3:

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VES No Geo-electric LOCATION Approximate thickness (m) Lithology Resistivity (Ωm) 1 211 - 276 BH 1 5.0 Lateritic Silt Sand 500 - 1000 20.0 Lateritic Sand 1000 – 527 13 Sand

2 439 - 414 BH 2 5.0 Lateritic Silty Sand 600 - 800 21.0 Lateritic Sand 900 – 1000 16 Sand

3 1000 BH3 3.0 Silty Sand 300 – 800 23.0 Lateritic Sand 900 - 1200 10 Sand

Field survey 2017

Soil Corrosivity property in the area is minimal (slightly corrosive) with apparent geo – electric resistivity of over 100Ωm. The geo-electric resistivity observed at the VES point 3 showed negligible contaminant impact with values close natural conditions.

4.7. Surface water system The impact of industrial toxics and hazardous wastes on aquatic life including microorganisms cannot be over-stressed. Consequently, upon the industrial revolution, many production and manufacturing companies have due to improper waste management techniques, added toxic and hazardous wastes including synthetic compounds into the aquatic environment. These wastes are also discharged into water without any treatment as a result of improper or deliberate channeling of the wastes into aquatic environment. The presence of these wastes in the environment causes extensive damage to the water quality characteristics and the ecology of the environment, especially when microbial degradation activities fail to remove these pollutants fast enough to prevent environmental degradation. The environmental consequences of marine pollution include creating a harsh marine environment which adversely affects activities of marine micro-flora as well as fish and other marine lives. Okulu stream takes its course form Ogale meandering through Agbonchia and serves as the Indorama complex treated effluent and rain water surface run-off discharge receiving water body. It flows

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IEFCL Train2 Fertilizer EIA Report from the East towards the West and changes direction South West towards the downstream. The Indorama complex treated effluent and rain water surface run-off is held in a retention pond and flows through a 1.10 km earth channel before emptying into the Okulu Aleto wetland.

4.7.1 Physio-chemical properties of surface water (Okulu) pH The water body is a fresh water body with pH slightly acidic at the upstream which is typical of the Niger delta surface water bodies. The pH during the rainy season fieldwork (2017) ranged from 6.80 to 6.95 and 6.55 – 6.60 at the Okulu River and control stations compared to 6.0 to 6.67 and 7.40 for control station for dry season sampling (2011). The values recorded complied to regulatory limit of 6-50 to 8.50. The trend analysis showed the recipient water pH values were more alkaline in the wet season than values obtained in the dry season. This could be as a result of run off of agricultural fertilizers applied to farms into the surface water and sand mining activities on the water body. However the observed pH values are normal for the Niger Delta (Ideriah et al. 2010) and within the recommended range of pH for natural surface waters. The change in pH was not significant and the various industrial activities around the study area (industrial treated wastewater discharge, mechanical and manual sand mining) have not significantly altered the pH of the water body.

Temperature Temperature of a water body is influenced by the condition of the weather, ambient atmosphere and temperature of runoff or effluent discharged into it. The temperature of the sampling stations during the dry season (March 2011) ranged from 24.8 to 25.1 oC and 25.2 at control station against 25.8 to 26.1 0C and 24.8 to 28.0 at the control stations. The fluctuation in temperature could also be attributed to the time of sampling, velocity and turbulence mixture of the sample.

Turbidity

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Turbidity is a measure of the degree to which the water loses its transparency due to the presence of suspended particulates. Turbidity is considered as a good measure of the quality of water. The suspended particles scatter the light, thus decreasing the photosynthetic activity of plants and algae, which contributes to lowering of dissolved oxygen concentration The turbidity values ranged from 9.30 to 49.8NTU and 1.13 for Okulu Stream and control station respectively during the dry season (March 2011) against 2.0 to 15.0 NTU and Control stations of 2.0 to 8.0 NTU in rainy season (September 2017). Sand mining activity is carried out on all sides and directions of the stream which serves as a major contributor to the high turbidity values of the water body. This statement agrees with past similar studies that streams are vulnerable to land use activities and accompanying run-offs which interfere with the stream characteristics. (Kiel 1997). The trend analysis indicated the turbidity was higher during the dry season compared to the wet season probably due to less volume of water which resulted to higher presence of particles and muddiness of water body. Total Dissolved Solids (TDS) Total Dissolved Solids are of concern due to their potential for causing unfavorable physiological reactions in both human and marine life. It is indicative of the amount of loads on a water body the higher the concentrations the more the loads. The TDS concentrations range from 66.0 to 201.0mg/l and 12.0 mg/l at the control in dry season as against the wet season of 23.0 to 115.0 mg/l and 18.0 to 72.0 mg/l at the control stations.

Total Suspended Solids (TSS) Suspended solids consist of an inorganic fraction (silts, clays, calcium, potassium, bicarbonates, chlorides, etc.) and an organic fraction (algae, zooplankton, bacteria and detritus) that are within the water column (GEMS, 1992).The TSS concentrations from fieldwork in March 2011 range from 32.6 to 62.8mg/l and 3.40 mg/l at control station as against the wet season (September 2017) concentration of 4.30 to 5.08 mg/l at sampling stations and 5.30 to 6.20 at control stations. The trend analysis indicated the TSS was higher during the dry season compared to the wet season probably due to less volume of water which resulted to higher presence of particles and muddiness of water body.

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Oxygen Demand The dissolved oxygen level during the dry season (March 2011) was ranged from 2.26 to 3.02mg/l and 3.40 mg/l at the control station. The concentration recorded during fieldwork September 2017 was 5.31 to 6.93 mg/l, while at the control station it ranged from 2.60 to 2.80mg/l. This result clearly shows the intense anthropogenic activities at the control stations (car washings, storm run-off and waste disposal) which may have influence on the result recorded within these stations. This implies that the Okulu stream has more carrying capacity than the control stations located in Eleme and Obi-Akpor LGAs. The Chemical Oxygen Demand level for the study area in rainy season (September 2017) ranged from 26.4 to 37.6 mg/l and 25.2 to 28.8 mg/l at control stations against dry season (March 2011) results of 8.0 to 9.40 mg/l and 7.0 mg/l at the control station. BOD concentration recorded indicate that the water body is not in any form of organic stress, as such have sufficient oxygen to handle organic load intrusion into the water body.

Heavy Metals The values of heavy metals determined were generally low and within their respective regulatory acceptable limits. The results showed concentration of the heavy metal such as Pb and Zn were moderately low, while vanadium, Chromium, Arsenic, Cadmium, Lead and Zinc were less than detectable limit of the instrument used. Some metal levels exhibited significant seasonal variation. The concentration levels might be attributed to anthropogenic enrichment arising from sand mining, abattoir, excavation activities as well as surface runoff from dumpsite in the area.

On the whole water quality data obtained in the area showed that the water bodies have low level alkaline earth metals and some heavy metals. The concentration levels of hydrocarbons was within the acceptable limits. The values of heavy metals determined were generally low and within their respective regulatory acceptable limits. Surface water in the Niger Delta has been recorded to contain high iron concentrations attributed to the metals being bound to the

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IEFCL Train2 Fertilizer EIA Report soil and sediment matrix. The intense manual sand mining observed during study is a confirmed contributing factor to high iron concentration. The physicochemical characteristics of the surface water indicate slight contamination of the recipient environment due to the ongoing sand mining activity on the water body. However the carrying capacity of the water body evaluated, is good.

4.7.2 Surface water microbiology Coliforms commonly referred to as indicators of recent contamination (bio monitors) of water were present in the surface water samples. The total coliforms ranged from 23 to 240 MPN/100ml for rainy season. The low prevalence of total coliforms, especially those of vegetative origins maybe attributed to the absence of several autochthonous species and supported by the prevailing environmental conditions and physicochemical characteristics of the surface water. Similarly, the total coliform counts in the control stations did not show any significant difference.

Table 4.7.1 Physio-chemical properties of Surface water (Okulu)

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Dry Season (2011) Rainy Season (2017) Up Mid- Down Agbonc Up Midstre Down Agbonc Rumuok FMEnv IFC stream stream Stream hia stream am Stream hia rushi LIMITS LIMITS River River Aquatic Control Control Life pH 6.00 6.67 6.07 7.40 6.80 6.90 6.95 6.60 6.55 6.0-9.0 6-9

EC us/cm 132 402 132 23.9 42 226 63 35 140 - -

Temperature oC 25.1 24.9 24.8 25.2 26.1 25.8 25.8 24.8 28.0 20-33 -

TDS (mg/l) 66.0 201 66.0 12.0 23 115 32 18 72 - -

Turbidity NTU 43.6 9.30 49.8 1.13 2 15 5 2 8 -

D.O mg/l 2.81 2.26 3.02 3.40 5.8 5.31 6.93 2.80 2.10 6.8 -

TSS (mg/l) 60.4 32.6 62.8 3.40 5.08 4.30 4.80 5.3 6.2 NS -

COD mg/l 8.0 9.0 9.40 7.0 28.8 37.6 26.4 28.8 25.2 40* 150

BOD5 mg/l 2.30 2.0 2.40 2.50 2.78 3.69 2.10 1.17 3.42 4.0 30

Total Hardness 113.2 0.83 19.7 22.5 10 12 10 12 12 NS

Nitrate (mg/l) 3.18 2.01 4.02 1.06 1.31 1.29 0.96 2.16 1.58 NS -

Sulphate (mg/l) 39.6 68.7 41.9 2.25 32.5 17.7 13.8 372.3 17.7 NS -

Phosphate mg/l 0.124 0.116 0121 0.032 0.08 0.06 0.19 0.20 <0.01 NS -

Chloride Cl- (mg/l) 15.18 16.3 15.2 6.84 30.0 12.0 15.0 6.0 10.0 - -

Magnesium (mg/l) 26.98 <0.001 4.20 5.40 0.26 0.18 0.13 0.14 0.12 - -

Calcium (mg/l) 0.82 0.332 0.968 0.92 0.39 0.02 0.01 0.03 0.01 - -

Nickel mg/l <0.001 <0.001 0.933 <0.001 <0.001 <0.001 <0.001 <0.001 <0.001 - -

Iron mg/l 0.165 2.031 1.070 3.53 0.43 0.26 0.12 0.22 0.01 1.0 -

Lead mg/l <0.001 <0.001 <0.001 <0.001 <0.001 <0.001 <0.001 <0.001 <0.001 0.05 -

Zinc (mg/l) <0.001 <0.001 0.022 <0.001 <0.001 <0.001 <0.001 <0.001 <0.001 50 -

Cadmium mg/l <0.001 <0.001 <0.001 <0.001 <0.001 <0.001 <0.001 <0.001 <0.001 0.002 <0.1

Manganese ( mg/l) <0.001 <0.001 <0.001 0.139 <0.001 <0.001 <0.001 <0.001 <0.001 NA

Vanadium mg/l <0.001 <0.001 <0.001 <0.001 <0.001 <0.001 <0.001 <0.001 <0.001 0.1

Chromium, mg/l <0.001 <0.001 <0.001 <0.001 <0.001 <0.001 <0.001 <0.001 <0.001 0.03 <0.1

Mercury mg/l <0.001 <0.001 <0.001 <0.001 <0.001 <0.001 <0.001 <0.001 <0.001 0.001 -

Arsenic mg/l <0.001 <0.001 <0.001 <0.001 <0.001 <0.001 <0.001 <0.001 <0.001 0.5 N/A

Oil and grease mg/l 1.20 1.40 1.80 <0.50 <1.0 <1.0 <1.0 <1.0 2.5 NS 10

Total Coliform (MPN 720 10 NA 110 93 240 23 75 1100 0 0 100ml-1) THB (x104cfu ml-1) 14.2 2.25 NA NA 2.40 X 6.20 X 1.70 X 2.10 X 4.20 X N/A N/A 103 103 103 103 104 THF (x103cfu ml-1) NA 0.60 NA NA 1.00 X 3.00 X 1.00 X 1.00 X 2.60 X N/A N/A 103 103 103 103 104 Source: EIA March 2011 and Fieldwork September 2017

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4.7.3 Sediment In aquatic ecosystem, the sediments act as sink and therefore preserve or retain the quality of the environment. The heavy particles or the insoluble fractions settle down on the bed as sediments. The nature and quality of sediment could also be determined from information on the status of the physico-chemical properties. Such information is also vital in determining the parameters that would also be responsible for specific changes and effects in this environment.

Table 4.7.2: Sediment results PARAMETERS SED1 SED2 SED3 SEDC1 SEDC2

Sulphide, (mg/kg) <0.01 <0.01 <0.01 <0.01 <0.01 2- Sulphate (SO4 ), mg/kg 434.10 51.83 483.46 362.73 185.73 - Nitrate (NO3 ), mg/kg 2.64 19.23 16.91 10.42 8.22 3- Phosphate (PO4 ), mg/kg <0.01 <0.01 <0.01 <0.01 <0.01 Total Organic Carbon (TOC),% 0.72 1.08 0.88 0.68 0.56 Total Petroleum Hydrocarbon 18.22 9.62 11.69 4.76 2.90 (TPH),mg/kg Total Coliform (MPN/100ml) >1100 >1100 160 460 >1100 Total Heterotrophic Fungi 5.10 X 104 8.70 X 104 4.60 X 104 5.20 X 104 1.47 X (cfu/ml) 105 Total heterotrophic Bacteria 9.60 X 104 1.01 X 105 6.50 X 104 8.40 X 104 3.60 X (cfu/ml) 105 Total Plate Count (cfu/ml) 1.17 X 105 1.42 X 105 1.00 X 105 1.10 X 105 4.40 X 105 Total Iron, mg/l 5.01 4.02 2.07 4.22 3.90 Sodium (Na),mg/l 0.55 0.63 0.22 0.45 0.56 Calcium (Ca) mg/l 22.05 19.77 22.77 24.05 21.65 Magnesium (Mg), mg/l, 10.88 9.88 12.05 10.76 9.42 Zinc (Zn), mg/l 39.7 19.03 22.65 20.05 17.44 Copper (Cu) mg/l 7.03 5.03 6.03 2.05 3.76 Manganese (Mn) mg/l 2.90 42.03 1.04 0.44 1.43 Total Chromium (Cr) mg/l <0.001 <0.001 <0.001 <0.001 <0.001 Nickel (Ni), mg/l <0.001 <0.001 <0.001 <0.001 <0.001 Lead {Pb} mg/l 0.32 0.33 0.21 <0.001 <0.001 Mercury {Hg} mg/l <0.001 <0.001 <0.001 <0.001 <0.001 Cadmium {Cd} mg/l <0.001 <0.001 <0.001 <0.001 <0.001 Arsenic (As),mg/kg <0.001 <0.001 <0.001 <0.001 <0.001 Vanadium (V),mg/kg <0.001 <0.001 <0.001 <0.001 <0.001 Cobalt (Co),mg/kg <0.001 <0.001 <0.001 <0.001 <0.001

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Silver (Ag),mg/kg <0.001 <0.001 <0.001 <0.001 <0.001 Source: Field work 2017 4.7.3.1 Sediment Physico-chemistry The color of the sediment samples ranged from black to dark grey coloration. The silt fraction was higher than the sand and clay content making the sediment Silty in texture. Nutrients are adequate to support the healthy growth of benthic population. The concentrations of nutrients in sediment around the study area are indicated below; Sulphate concentrations varied from 51.8 to 483.5 mg/kg and 185.7 to 362.7 mg/kg for rainy season (September 2017) nitrate content ranged from 2.64 to 19.23 mg/kg and 8.22 to 10.42 mg/l at control stations for rainy season. Total Petroleum Hydrocarbon was low for all samples taken 9.62 to 18.22 mg/kg and at control stations with 2.90 to 4.76 mg/l for rainy season. This implies that the sediment along the study area is slightly contaminated with petroleum hydrocarbons resulting from the mechanical dragger on the water body. The heavy metal concentrations are low in the sediment samples and there is no indication of their accumulation in the samples. Mercury and Arsenic were very low and below detection limit in the sediment samples.

4.7.3.2 Sediment Microbiology The microbiological data obtained from the analysis of the sediment samples. The hydrocarbonoclastis (Hydrocarbon Utilizing Bacteria and Fungi) were not detected in the sediment, showing the low hydrocarbon burden and thus corroborating with the absence of hydrocarbon contamination in the sediment sample. The low hydrocarbonoclastic counts in the study area and control station further lends credence to the sediment physicochemical results as also described by Atlas (1981). Furthermore, the bacterial genera isolated in the sediment include Pseudomonas, Klebsiella, Proteus, Bacillus, Staphylococcus, Serratia, Micrococcus, Flavobacterium, Enterobacter, Achromobacter and Arthrobacter. The fungal isolate mainly belonged to the genera Fusarium, Aspergillus, Candida, Mucor and Penicllium.

4.8 Hydrobiology 4.8.1 Phytoplankton

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A total of forty-eight (48) phytoplankton species representing four (4) major classes were identified in the study area in both climatic regimes (dry and wet seasons). The four classes include: Bacillariophyceae (diatoms), Chlorophyceae (green algae), Cyanophyceae (blue green algae) and Euglenophyceae.Bacillariophyceae formed the most dominant group of phytoplankton in the wet season with a percentage composition of 42.27%. Similarly, in the dry season the percentage composition was 29.83% which is about 1 fold decrease. The seasonal changes in the species composition and population density may be attributed to the changing environmental conditions, increase in nutrients from surface runoff during the dry season and deposition of organic matter. However, the surge in the population of Bacillariophyceae may be attributed to their ability to grow under relatively low temperatures which are less suitable for other algae (Wanganeo and Wanganeo, 1991). The findings compare favourably with Davies et al, 2009; Allison and Otene, 2012; Lund, 1965 and Munawar, 1974 for similar ecosystems. The population density ranged from 2 to 43 cells/1000L in the dry season and 12 to 24 cells/1000L in the wet season. Well represented taxa in the wet and dry season include: Cyclotellaspp, Naviculaspp, Melosiraspp (Dry season); Navicula cuspidate, Nitzschiaclosterium, Amphora ovalis, Nitzschia frigida, Tabellaria fenestrate (wet season). The Bacillariophyceae depicted bimodal growth in the wet season especially in the upstream of the Okulu stream. This may be attributed to the deposition of nutrients during these peak periods (Kaul, et al, 1978).

The Chlorophyceae formed the second most dominant group of phytoplankton in the wet season (34.02%) with a population density of 6 to 20 cells/1000L and 0 to 12 cells/1000L in the dry season (12.41%). Peak values in the wet season may be attributed to change in environmental conditions. Bimodal wet season peaks were also observed in the upstream and downstream of the Okulu stream which may be attributed to influx of nutrients into the Okulu stream. Furthermore, due to runoffs during the wet season, there was a massive introduction of cosmopolitan species in the Okulu stream (SW1 and SW2) compared to the control stations and the dry season (SW2, SW3 and SW4). Well represented taxa include: Closterium lineatum, Micrasterias radiata (wet season) and Rhizocloniumspp, Chlorella spp (dry season).

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The Cyanophyceae maintained a population density of 0 to 172 cells/1000L in the dry season and 6 to 9 cells/1000L. Coelosphyaeriumspp, Oscillatoriaspp and Anabaena limneticawere well represented in the dry and wet seasons and contributed significantly to the cynophyta population. The Cynophyceae depicted unimodal peak growths downstream in the wet and dry season. This may be attributed to increase nutrients levels and temperature variations in the downstream. High temperatures have been known to act as a principal factor causing blooms of Cyanophyceae (George, 1960).The order of dominance was: Bacillariophyceae >> Chlorophyceae >> Cyanophyceae >> Euglenophyceae (Wet season); Cyanophyceae >> Bacillariophyceae >> Chlorophyceae (Dry season).

Diversity indices In the dry season, the Shannon-Weiner index ranged from 0.06 in the downstream to 1.44 around the outfall area of Okulu stream, while during the wet season it ranged from 2.67 to 3.01 in upstream and control station respectively. The ecological indices suggest low dominance of these aquatic organism probably due to disturbed habitat as a result of sand mining through their eggs, thus hampering their reproduction capacity. Furthermore, the evenness values reflect poor distribution of species especially in the dry season. The population density of Bacillariophyceae, Chlorophyceae and Cyanophyceae in dry season supports the poor distribution of phytoplankton, as during this period there are no water influx into water body with nutrient to attract these organism to increasing their presence/dominance during this period.

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Table 4.8.1: Phytoplankton species composition and distribution in the study area (Dry season) Taxa W1 SW2 SW3 SW4 SW1 Total %Total Bacillariophyta Naviculaspp 0 0 0 0 13 13 Nitzschiaspp 1 0 0 0 7 8 Fragilaria 0 0 0 0 4 4 crotonensis Cyclotellaspp 0 2 75 2 2 81 Melosiraspp 0 0 0 0 17 17 Synedraspp 1 1 0 0 0 2

Subtotal 2 3 75 2 43 125 29.83

Chlorophyta Chlorella spp 0 3 12 0 0 15 Rhizocloniumspp 0 0 0 0 37 37

Subtotal 0 3 12 0 37 52 12.41

Cyanophyta Coelosphyaerium 0 22 48 172 0 242 spp

Subtotal 0 22 48 172 0 242 57.76

Taxa_S 2 4 3 2 6 Individuals (cells/1000L) 2 28 135 174 80 Shannon_H 0.69 0.74 0.91 0.06 1.44 Evenness_e^H/S 1 0.50 0.82 0.08 0.80

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Margalef 1.44 0.90 0.41 0.19 1.14 Dominance_D 1 0.38 0.56 0.02 0.71 Source: Field survey, 2011

Table 4.8.2: Phytoplankton species composition and distribution in the study area (Wet season) Taxa SW1 SW2 SW3 SW4 Control Total %Total Class: Bacillariophyceae Amphora ovalis 1 5 1 0 1 8 Amphora spiroides 0 0 0 1 0 1 Nitzschia frigida 5 0 1 0 1 7 Nitzschiagracilis 0 1 5 1 1 8 Nitzschiaclausii 1 0 0 1 1 3 Nitzschia closterium 0 7 1 1 0 9 Cyclotella stigmata 0 1 0 0 5 6 C. operculata 1 0 1 0 1 3 C. centralis 0 1 0 1 0 2 Melosiravarians 1 0 1 0 1 3 Naviculagracilis 1 5 0 0 0 6 N. cuspidate 3 1 1 5 1 11 N. ovalis 1 0 0 0 1 2 Synedra ulna 2 0 0 0 3 5 Tabellariafenestrata 1 3 1 2 1 8

SUBTOTAL 17 24 12 12 17 82 42.27

Class: Cyanophyceae Oscillatoriaindica 3 0 1 0 1 5 O. limnosa 0 1 1 2 1 5 O. major 1 0 3 1 0 5 O. obscura 0 1 0 0 1 2 O. miniata 1 1 1 2 0 5 Anabaena affinis 0 1 0 0 1 2 A. flos-aquae 1 0 1 0 0 2 A. laxa 1 1 0 1 1 4 A. limnetica 0 3 1 0 1 5 A. affinis 1 0 1 1 0 3

SUBTOTAL 8 8 9 7 6 38 19.59

Class: Chlorophyceae Closterium gracile 0 2 0 2 2 6 C. littorale 6 0 0 0 0 6 C. navicula 0 3 0 0 3 6 C.lineatum 3 0 6 1 1 11

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C. parvulum 0 6 0 0 0 6 C. kuetzingii 4 0 0 2 0 6 Eudorinaelegans 0 1 0 0 1 2 E. cylindrica 0 0 3 1 0 4 Scenedesmusacuminatus 0 0 0 0 0 0 S. quadricauda 3 1 0 0 0 4 Cosmariumsp 1 3 0 0 0 4 Micrasteriasapiculata 0 1 0 0 1 2 Micrasterias radiata 3 2 2 0 2 9

SUBTOTAL 20 19 11 6 10 66 34.02

Class: Euglenophyceae Euglena caudata 1 0 5 1 1 8

SUBTOTAL 1 0 5 1 1 8 4.12

SUMMARY Taxa_S 23 22 19 17 24 Individuals (cells/1000L) 46 51 37 26 34 Shannon_H 2.91 2.83 2.67 2.68 3.01 Evenness_e^H/S 0.93 0.92 0.91 0.96 0.97 Margalef 5.75 5.34 4.98 4.91 6.52 Dominance_D 0.95 0.95 0.94 0.95 0.97 Source: Field survey, 2017

4.8.2 Zooplankton The zooplankton community in the project area comprises Copepoda, Rotifera, Tintinidae, Cladocera and Cichlidae in the wet and dry season. A total of 4 species were identified in the dry season and 15 species in the wet season. In both climatic regimes, the Rotifers were the most dominant zooplankton taxonomic group representing about 72.14% and 42.86% in the dry and wet season. The population density ranged from 0 to 11 cells/100L in the dry season and 3 to 10 cells/100L in the wet season. The most abundant species in both climatic regimes were Keratella cochlearis and Lecane sp. The dominance of the Rotifers is not uncommon as it has been reported in other fresh water bodies (Vermaet.al, 2013; Kar and Kar, 2016). The dominance of Rotifers may be attributed to the presence of sediments in suspension in the surface water bodies (Kirk and Gilbert, 1990). Several species of rotifers are known to tolerate high concentration of water pollution as they are tolerant to different types of suspended materials in the water bodies.

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Furthermore, the Copepoda and Cladocera are classified as the most important component of the zooplankton community. The copepods consist of 1 species in the dry season and 4 species in the wet season with a percentage composition of 20.69% and 27.14% in the dry and wet seasons. The low taxa number in both climatic regimes maybe attributed to the sand mining activities in the water body which constantly disturb the habitat of these organisms there by preventing them from reproducing through destruction of their eggs. The copepoda population in the dry season ranged from 0 cells/100L in the upstream and downstream of Okulu stream to 4 cells/100L around the outfall area. In the wet season, the population density ranged from 1 cells/100L to 10 cells/100L around the downstream. The most abundant species in the wet and dry season include: Copepod nauplius, Diaptomusspand Metacyclops sp. The Cladocera were relatively absent in the dry season. In increasing order, the dominance pattern of the zooplankton community were Rotifera >> Copepoda >> Tintinidae (Dry season); Rotifera >> Copepoda>>Cladocera>>Cichlidae (Wet season).

Diversity indices The Shannon-Weiner diversity index for the zooplankton taxonomic group in the surface water bodies ranged from 0 to 0.87 in the dry season and 1.83 to 2.10 in the wet season. This variation is envisaged in any surface water body owing to the fact that during the wet season surface water body received influx of water, which are made up of different sources ranging from animal/human waste, as such have the capacity increase the diversity of aquatic organism. The species evenness showed a poor distribution across the sampling stations in the dry and wet season, which is as a result of intense mechanical and manual sand mining ongoing in the Okulu stream, thus disturbing the habitat of these aquatic organism. The maximum evenness in the dry season was 0.78 around the outfall area of the Okulu stream and 0.97 around the control stations in the dry season. The results indicate a consistently low zooplankton population with poor identical values.

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Table 4.8.3: Zooplankton species composition and distribution in the study area (Dry season) Taxa W1 SW2 SW3 SW4 SW1 Total %Total Order: Copepoda Copepod nauplius 0 0 0 2 4 6

Subtotal 0 0 0 2 4 6 20.69

Rotifera Keratella cochlearis 0 0 0 9 11 20 Kellicotiaspp 0 0 0 1 0 1

Subtotal 0 0 0 10 11 21 72.41

Tintinidae Tintinid larva 0 0 0 0 2 2

Subtotal 0 0 0 0 2 2 6.90

Taxa_S 0 0 0 3 3 Individuals (cells/100L) 0 0 0 12 17

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Shannon_H 0 0 0 0.72 0.87 Evenness_e^H/S 0 0 0 0.62 0.78 Margalef 0 0 0 0.80 0.71 Dominance_D 0 0 0 0.44 0.54 Source: Field survey, 2011

Table 4.8.4: Zooplankton species composition and distribution in the study area (Wet season) Taxa SW1 SW2 SW3 SW4 Control Total %Total Order: Cladocera Alonasp 0 0 0 1 0 1 Bosminaaffinis 1 0 1 0 1 3 Bosminadiaphana 1 1 0 1 0 3 Polyphemus sp 5 0 1 0 1 7 Moinasp 1 0 0 1 0 2

SUBTOTAL 8 1 2 3 2 16 22.86

Order: Copepoda Mesocyclopssp 1 0 0 0 3 4 Diaptomussp 1 5 1 0 0 7 Eucyclopssp 0 0 0 1 0 1 Metacyclopssp 1 5 0 0 1 7

SUBTOTAL 3 10 1 1 4 19 27.14

Order: Rotifera Lecanesp 0 5 1 1 1 8 Euchlanissp 0 4 1 0 1 6 Collothecasp 5 0 0 1 0 6

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Keratellasp 1 0 1 1 1 4 Asplanchnasp 3 1 0 1 1 6

SUBTOTAL 9 10 3 4 4 30 42.86

Cichlidae Tilapia sp (fry) 0 1 3 0 1 5

SUBTOTAL 0 1 3 0 1 5 7.14

Taxa_S 10 7 7 8 9 Individuals 20 22 9 8 11 (cells/100L) Shannon_H 2.03 1.74 1.83 2.08 2.10 Evenness_e^H/S 0.87 0.90 0.96 1 0.97 Margalef 3.00 1.94 2.73 3.37 3.34 Dominance_D 0.88 0.84 0.92 1 0.95 4.8.3 Benthic fauna The Benthic invertebrates were represented by three taxonomic groups in the wet and dry season. The taxonomic groups are Oligochaeta, Insecta and Nauplii comprising of 4 taxa in the dry season and 10 taxa in the wet season. The insect dominated the benthic fauna community with a percentage composition of 75% in the dry season and 52.38% in the wet season. The dominance of Insecta is not uncommon in freshwater ecosystems as it has been reported to tolerate extreme conditions and high competitive capacity (Di Giovanni et al., 1996). The dominance of this taxonomic group of organisms suggests enrichment by organic matter in the sediments (Dévai, 1990). This agrees with the analytical results of the sediments in the study area.

Furthermore, the Oligochaetes were the second most dominant benthic invertebrates in the study area comprising about 25% composition in the dry season and 38.10% in the wet season. The population ranged from 0 to 3 cells/m2 in the dry season and 1 to 3 cells/m2 in the wet

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Diversity The Shannon-Weiner diversity index for the Benthic invertebrates in the dry season ranged from 0 to 0.85 and 0.69 to 1.79 in the wet season. The sharp variation noticed in wet season is possibly due to erosional process of water influx into the water body from animal feed lot and agricultural farm land within the water body which may has increase the dominance of Benthic invertebrates during the wet season as observed in the diversity index. This may be responsible for the sparse population of benthic fauna across the sampling stations. The results of the evenness index were low in both climatic regimes.

Table 4.8.5: Benthic invertebrates composition and distribution in the study area (Dry season) Taxa W1 SW2 SW3 SW4 SW1 Total %Total

CLASS: OLIGOCHAETA Oligochaete worm 0 0 0 3 0 3

SUBTOTAL 0 0 0 3 0 3 25

CLASS: INSECTA Chaoboruslarvae 0 0 0 0 2 2 Chironomus larvae 0 0 0 0 6 6 Simulium larvae 0 0 0 0 1 1

SUBTOTAL 0 0 0 0 9 9 75

Taxa_S 0 0 0 1 3 Individuals (cells/m2 ) 0 0 0 3 9 Shannon_H 0 0 0 0 0.85 Evenness_e^H/S 0 0 0 0 0.74 Margalef 0 0 0 0 0.91 Dominance_D 0 0 0 0 0.56 Source: Field survey, 2011

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Table 4.8.6: Benthic invertebrates composition and distribution in the study area (Wet season)

Taxa SD1 SD2 SD3 SD4 Control Total %Total CLASS: OLIGOCHAETA Deroobtusa 2 0 0 0 1 3 Ophidoniassp 0 0 1 0 0 1 Dugesiapolychroa 1 0 0 0 1 2 Lumbricussp 1 0 1 0 0 2

SUBTOTAL 4 0 2 0 2 8 38.10

CLASS: INSECTA Chironomoussp 0 1 0 0 1 2 Corduliasp 0 2 0 0 0 2 Donaciasp 1 0 0 1 1 3 Dytiscussp 0 0 1 0 0 1

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Poissoniasp 1 0 0 1 1 3

SUBTOTAL 2 3 1 2 3 11 52.38

Nauplii 0 1 0 0 1 2

SUBTOTAL 0 1 0 0 1 2 9.52

Taxa_S 5 3 3 2 6 Individuals 6 4 3 2 6 (cells/m2 ) Shannon_H 1.56 1.04 1.10 0.69 1.79 Evenness_e^H/S 1 1 1 1 1 Margalef 2.23 1.44 1.82 1.44 2.79 Dominance_D 0.93 0.83 1 1 1 Source: Field survey, 2017

4.8.4 Fisheries 4.8.4.1 Fishery Composition of the Study Area Fishing activities in the surface water bodies around the project area are generally subsistent and nearly absent in the last few years. The fishery resources in these lentic systems have been severely threatened with increasing manual and mechanical sand-mining activities. During the field data gathering exercise, there was no presence of artisanal fishing activities in the Okulu stream.

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The analytical result of the aquatic ecosystem in both climatic regimes (Surface water quality, Sediment quality and Hydrobiology) which are far below threshold limits set by regulatory agency indicate sufficient carrying capacity of the Okulu stream.

4.9 Waste Management The solid waste generation during construction and operation phase and their disposal summarized as below: During construction generated waste will includes metal scraps, wood, glasses, paper, cements bags, empty containers, spent oil from vehicles and heavy earth movers. Construction wastes will be segregated, collected and disposed in accordance with statutory guidelines. Comprehensive list of expected waste during the construction is presented in table 4.9.1 with their respective management strategy.

Table 4.9.1: Expected Waste Types/management strategy during the Construction Phase Waste Type Management Strategy Soil cuttings Clean fill, levelling and landscaping. Wood Reuse, Empty Cement Bags Reuse, incineration Empty container Decontamination and sale Metal scraps, Cables Sale Spent Oil Sale/ Incineration Food waste Composting at approved dump site by accredited waste vendor Paper waste Recycling Plastic bottles and sachets Recycling/Incineration

Operation Phase: Domestic solid wastes will be collected, segregated and disposed of in the approved manner by accredited waste vendors and to the satisfaction of the Nigerian environmental and waste management regulations.

Table 4.9.5: Expected Solid waste generation in the operation phase, sources as well as their management strategy Solid Waste Source Management Strategy Metals Maintenance Collection in the scrap yard for reuse or sale Battery Control room, Forklifts etc Supplier of new battery takes the old battery; disposal by used battery

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accredited third party vendor. Biomedical Clinic Incineration Electric bulbs and E- Plant, offices, clinic, Collection in dedicated receptacles; waste control room disposal by accredited third party vendor. Food waste Offices and plant Collection in dedicated receptacles; disposal by accredited third party vendor. Oil soaked cotton Plant, maintenance Incineration Paper, plastic Offices and plant Recycling; incineration. Polymer Waste Waste chemical stack, Incineration water treatment plant

Waste management Strategy Generally, the existing waste management strategy in Indorama complex includes waste reduction, waste reuse, waste recycling, and final disposal by an accredited waste management vendor. This strategy emphasizes on prevention of waste, followed by reduction, reuse before recycling, recovery and lastly disposal to an approved dumpsite using an accredited waste vendor manifested to ensure cradle to grave. The philosophy behind this 4Rs is to cut down waste generation to a manageable volume for final disposal. Wastes contribution from the proposed new plants will add to the existing waste stream in the Indorama Complex will be handle by the existing waste management facility.

4.10 Socio-economic 4.10.1 Study Settlements A well-defined area has been considered for the Socio Economic Impact Assessment. This area covers 4km radius from IndoramaComplex. In the area under consideration four(4) main settlements are detected:Agbonchia, Aleto,Akpajo, in Eleme Local Government Area and Elelenwo in Obio/Akpor. Elelenwo is of Ikwerre origin. Among Aleto and Agbonchia

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IEFCL Train2 Fertilizer EIA Report settlements, there are also three family units, respectively Okerewa, Njuru and Akpankpan, whose creations were to ensure adequate community welfare packages to the host communities by the Indoramamanagement.Okerewa is studied under Aleto, while Njuru and Akpakpan are covered under Agbonchia. Such settlements have been considered for the study since they are the nearest to the proposed IEFCL-Train2 project, in which the major social impact related to the project are expected. The people of Eleme claim a common ancestry, language and ethnicity.

4.10.2 The Eleme Communities Eleme is a kingdom and the current traditional head king Oluka Ejire, the Onne-ehEleme is a government recognized 1st class chief. Although Ogale is the traditional headquarters of Eleme kingdom, the present ruler hails from Agbonchia. Eleme shares boundary with other ethnic groups in Rivers State like Ikwerre, Okrika, and Ogonis. The language of Eleme also borrows from these neighbours and shares strong similarities with Ogoni. There are two clans in Eleme: Odido and Nchia; the study communities belong to the Nchia clan.

There is a hierarchical order of leadership whereby the paramount ruler is at the apex and the ordinary citizen is at the bottom. In-between the hierarchy are family heads or chiefs who usually sit with EmereEleme in Council. Within the leadership structure are influential groups such as the Community Development Committee (CDC) and the youths. The CDC comprises representatives from the various units that make up the community. Notable individuals are co-opted as members if they feel that they could be resourceful in contributing to the progress of the community even if they are not initially proposed from their units. Rise in the proportion of young people who become exposed to modern lifestyle, education and attitudes has brought youthful exuberance to the fore. The Youths Council in Eleme are active in conversing issues such as employment, scholarship, industrial relations and culture. Accordingly, sub committees of the Youth’s Council are formed to address the various challenges they face. Another group with influence in Eleme is the women head chiefs in the

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IEFCL Train2 Fertilizer EIA Report various sub-clans. Other groups in the community are peer groups, age grade, trade groups and social clubs. For these other groups their aspiration and influence is limited to the welfare of their members.

4.10.3 Elelenwo Community The people of Elelenwo are descended from Obio after whom Obio/Akpor local government area of Rivers state is named. Obio had two sons called Evo and Apara. Under Evo, there are three clans EvoKpotoma and Esara. Kpotoma has six communities namely Rumuluku, Rumuenyeron, Rumueziolu, Rumuoduwere, Rumueheleze and Rumuodani. Elelenwo comprises sections of the last three communities. Rumuodani is the community whose land is part of the territory that was acquired by the Federal government to build the then Eleme Petrochemical complex. Elelenwo traditional leadership has a committee of the three clans whose chairman is the paramount ruler of Elelenwo. The headship is rotated so that every clan at some time have the chance of leading the community. For Elelenwo as a whole, there is a community development committee, youth council, women group and Owhor holders (Ikwerre traditional priesthood). These various groups are like arms that govern Elelenwo community.

In this survey, respondents weighed the relative degree of influence among the categories described above. In community governance; chiefs were rated highest, followed by the youths, elders, women and age grade.

Settlement Pattern Settlement pattern in the study area is nucleated. All the settlement layouts are densely built and occupied with streets and lengthy roads. It is likely that they all began as linear settlements along the old Bori road, but the evidence now is of settlements with internal structures that spread deep from the main thoroughfare. The internal structures of the settlements have not matured to a point where they acquire distinctive functional properties like commercial, residential or public uses. These settlements are all struggling to

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Demography The Eleme people are an enthusiastic and aspiring group of people. Eleme is a local government area in Rivers State, Nigeria, located east of the Port Harcourt LGA; it is part of the Greater Port Harcourt metropolitan area. It covers an area of 138 km2 and at the 2006 Census had a population of 190,194. Its headquarters was changed from Nchia to Ogale by the legislative council. The territory known as Eleme constitutes one Local Government Area out of the 23 that make up Rivers State and is located between longitude 7′ and 7′ 35” (seven degrees thirty-five minutes) East of the Meridian and latitudes 4′ 60” and 4′ 35” (four degrees sixty minutes and four degrees thirty-five minutes) North of the Equator. The area is about 138 square kilometers

Occupation, Employment and Income The distribution of occupation among the respondents is 48 per cent for the self-employed, 21 per cent for those who work in government offices, 12 per cent for company workers and 22 per cent unemployed (See Figure 4.10.2). The self-employed are more in Agbonchia and Elelenwo than in Aleto and Akpajo. Likewise too, Aleto and Akpajo have more government and company employees than the other settlements. The highest rate of unemployment was reported in Agbonchia and the least in Akpajo. The occupation of the self-employed are business(small scale business and contractors to IEPL (56%), farming (29%), trading (12%) other (14%). Those categorised as other include, clergy and church workers, artisans, transport workers, etc. Majority of the businessmen are suppliers to the large companies in the area. Only 2 per cent of the respondents claim they fish. The settlements surveyed have rivers where they can fish, but this vocation is dying because of the heavy exploitation of the sand resource of the river. There is at present monthly monitoring of the river by IEPL. This axis of greater Port Harcourt is one of the major sources of sand used by the construction industry in Port Harcourt.

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Figure 4.10.4 Employment Distribution in the Study Settlements

The mean daily income of people in the study area is N400 or 2.6 USD per head per day. This is below the national minimum wage of N18, 000/month, but above 2 USD (where 1 USD = N154) required by individual to escape extreme poverty. It should be noted however that the national minimum wage is paid to individuals who may be heads of households and its overall impact will be significantly below what a household require for its sustenance. Divided into quintiles in Table4.10.3the income profile of the study area portrays a very grim image of extreme poverty for the majority of the population. At 20 per cent intervals, the lowest groups earn 3 per cent of the total income, the second lowest earn 7 per cent, the middle group earn 10 per cent, and the fourth earn 16 per cent, while the highest earn 64 per cent. Table 4.10.2: Wealth Quintile of Study Settlements Wealth Percentage (%) Daily income Quintile per-capita Lowest 3% 0.3 USD Second 7% 0.5 Middle 10% 0.9 Fourth 16% 1.4 Highest 64% 5.6 USD Source: EIA (2011)

Twenty per cent of the population of the study settlements earn 64% per cent of the income with an average 5.6 USD per capita. The remaining 80 per cent of the population

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of the study area live on an average per capita of 0.78 USD. We can categorically state that 80 percent of people in the study settlements live under extreme poverty in 2011. Poverty is increasing in the area, although nationally thought to be dropping due to Nigeria’s strides towards its eradication through the pursuit of the Millennium Development Goal 1 (FGN, 2004).

Commerce and Industry In the Port Harcourt Master Plan 75 the settlements surveyed in this study are located in the north eastern axis designated for heavy duty industries.The state-of-affairs is that the large industrial complexes have not attracted medium manufacturing industries to utilizetheir products. This lack of backward integration permeates to the low level of small aspiring entrepreneurs. There are no signs of industrial activities at the community level in the study settlements. As reflected in the occupation structure, people either farm, work for government or they are businessmen. Being a businessman simply means that one is a vendor to many of the large industrial complexes in the area. What remains of industries that community members can relate to are small time welding and fabrication, sand mining in all the rivers in the area, traditional food processing like fish smoking and cassava flour production. The presence of the large industries, the local government headquarters of Eleme and a large population means that there are commercial activities. In the formal sectors are many commercial bank branches, retail outlets, small hotels, and asphalt plants. In the informal sector there are many petty trading activities, automobile mechanics, local transport business, eateries and building construction. The informal commercial sector is the most numerous business activities in the area. Every community own a market; some are periodic while others are daily. The Nchia market (Plate4.10.2) is the largest of the daily markets. Two periodic markets are famous in the area: the Nim market (also called Ikwurugba) trades every fifth day in Elelenwo and the Echietaejiemarket of Agbonchia which trades only on Sunday. These two markets have patrons from across Rivers State and beyond.

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Plate 4.10.2: Front view of the Nchia ultramodern market in Eleme

Agriculture and Land Practices Land ownership and the rules of transfer are strict and contentions in the settlements. Distant lands from the community are devoted to agriculture. The crops cultivated in their order of importance are cassava, maize, yam, plantain, green vegetables, cocoyam, tree crops, and fruits. The farming system is a limited form of shifting cultivation whereby a land is cleared and cultivated for several years until productivity diminishes; it is then abandoned until natural processes regenerate the soil. The fallow period was up to 7 years about 30 years ago it reduced to about 4 years 10 years ago, but now the farms are rarely left fallow as illustrated in Figure4.10.3.

The strategy adopted in maintaining productivity is to rotate the crops and interplant. The cycle is to clear the land manually of short shrubs or remnants of the previous year crops burn the clearing in a heap, then intercrop with maize and cassava, maize and melon and cassava or green vegetables (like okra and pumpkin) with cassava. The farmer staves off hunger by harvesting the quick maturing maize, melon and vegetables, while waiting longer (6-9months) for the maturation of cassava and yam. Most farms are dotted with economic trees like raffia palm, oil palm and fruit bearing trees like mango and pear, which also contribute to the sustenance of the farmers’ household.

Farming tools and inputs are also basic. Seedlings are obtained from the previous year’s harvest. Cutlasses, hoes and spade make up the farming tools. Mechanization is non- existent. There is a subtle move to improve productivity through the application of inorganic fertilizers, but their availability is limited and cost too high for the subsistent farmers. The process of burning farm waste also adds some manure (potash) to the soil because crops perform better on spots where such burning takes place.

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The defunct International Institute for Tropical Agriculture (IITA) in Onne also spearheaded the introduction of mosaic resistant cassava varieties in the 1980s that provided the leap cassava gained as the prime crop cultivated in the area. The secrete of cassava being the chief crop of the area is that it require less fertile soil than yam, requires less maintenance than yam, and it has a higher yield per hectare. Moreover, the cropping material (stem) for cassava is easily generated compared to yam seedling.

Inheritance is the most common means by which respondents in the study area gain access to land. The least means through which people gain access to land is by pledge or as a gift. Rapid urbanization is changing the way people gain access to land in the study. It is observed that in Akpajo and Elelenwo that are close to Port Harcourt city, and therefore the most urbanizing, purchase of land is as popular as inheritance. Pledging which involves mortgaging a piece of land in lieu of payment or borrowed money is also more common in Elelenwo than in other settlements in the study.

Water Supply and Sanitation The sole source of domestic water supply is shallow boreholes. The water tables in the study areas are close to the surface and water can be tapped at 10m in most cases from the first aquifer. All domestic water supplies in the study area rely on this ubiquitous method. It is augmented by rainfall during the peak of the rainy season when the harvest is cleaner. Settlements around industrial Complex show ever complain that sometimes their rainwater is polluted by emissions washed out from the various plants nearby.

A more comprehensive study of domestic water supply in the study areas by NDDC (2008) (seeTable4.10.2) shows that majority of households in the study area rely on outdoor taps (usually boreholes) for their water supply. Another proportion sinks the boreholes in their premises, and then pipes the water to their houses. Others use land dug wells and streams as their source of water supply.

Table 4.10.3: Percentage Distribution of Household Water Sources LGA Piped Outdoor tap Well River Vendor Other

Eleme 8.1 41.4 16.2 24.2 6.1 4.0

Obio/Akpor 27.2 54.4 17.8 0.0 0.6 0.0 Source: NDDC (2008)

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The study settlements are covered by the activities of the state sanitation authority, responsible for the evacuation of refuse in Port Harcourt and its immediate neighborhoods. Most respondents, especially in Akpajo and Elelenwo attribute the management of waste in their domain to the sanitation authority. They however complain about paucity of collection sites which prompt people to also use nearby bushes, vacant plots and their backyard as dumping grounds. These methods of disposal are present in every study community. The picture in Plate 4.10.3 was taken at the vicinity of the Nchia Ultramodern market. Dumps like this litter the host communities and proves the inadequacy of waste segregation, storage, collection and disposal Depending on the type of refuse and the season, burning is used by the citizenry to minimize the nuisance and unhealthy situation rounding waste management in the area.

Plate4.10.3: Refuse Dump adjoining the Nchia Ultra Modern Market

The flushing of toilets into septic tanks and soak away are the commonest means of excreta management. Ideally, the septic tank should be evacuated when due but not later than six months; however that is not the case in the study area. Another observation with the use of septic tank as retainer for sewage is that the owners are oblivious of the fact that boreholes for domestic water supply are often sited close to these septic tanks. There are no clear cut regulations on this in Nigeria but, the practice elsewhere is that boreholes cannot be sited less than 200m from a septic tank (Ede and Edokpa, 2010). This calls to question the quality of water sourced from boreholes as practiced in the study area. The other important means of excreta disposal in the study area is covered pit latrine and it is nearly as prevalent as the water closet system. People also use surrounding bushes, water channels and the pail system to manage their excreta in the study area.

Transportation

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The four settlements in the study area are traversed by two major highways: the East-West Road that begins from Warri and end in Eket and the Port-Harcourt-Aba Expressway. The two roads are in fairly good and are always busy. It is from these major roads that the internal road arteries emanate. Most of the internal roads are not paved. In Aleto and Agbonchia NDDC paved some roads, but most of them have failed and are un-useable at some points. The problems with the NDDC roads are that they have very poor foundation and no concrete basebefore the asphalts were laid. Sometimes they do not have drainages; where drainage exists, they channel water to nowhere, which contributes to the road failure. Movement from one place to another is by road in the study settlements. All the study settlements are big enough to require some sort of transport and it is met through the use of tricycles and motorcycles. Motorcycles stand on left of the plate 4.10.4 on Agbonchia – Oyibo road.

. Plate 4.10.4: Motorcycles are Important Means of Transportation in Eleme

Education Every community in this study has a model primary school, recently constructed or under construction, as in Plate 4.10.6, that is publicity funded. All the settlements except Akpajo also have a secondary school owned by the government. All the communities have benefited from the new primary schools project by the state government, who have vowed to equip them with modern facilities like computers, laboratories and well trained teachers. Construction work in some of these schools like the one in Akpajo has been completed, but is yet to be equipped and put to use. Privately run schools from primary to secondary levels are present in all the settlements. These private schools sometimes may offer teaching standard that are higher than those in government schools, but their fees are usually exorbitant. They nevertheless provide opportunity and choices to parents and pupils.

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Plate 4.10.6: Model Primary School in Elelenwo –Obio-Akpor LGA built by Indorama

Table 4.10.4: Educational Level of Study Area Educational Attainment by Household Members.

Categories Obio- Akpor Eleme % No formal 375 457 13.3 Education Pre-primary 213 162 6.8 Education Primary Comp. 341 231 12.3 Secondary 238 216 11.6 Uncompleted Secondary 312 478 13.5 completed Tertiary 98 104 4.9 Uncompleted Tertiary Completed 476 337 13.3 Teachers Grade2 236 176 9.5 Trade test cert. 128 118 5.9 City and Guild Cert. 287 101 8.9 TOTAL 2704 2380 100

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Sources: Field survey, 2012 and LGAs publications (various editions).

According to NDDC (2008), adult literacy rate in Eleme is 82.3 per cent while in Obio/Akpor it is 85.5 per cent. The 2008 demographic and health survey of Nigeria says adult literacy rate in the south-south is 68.6percent for women and 80.2 percent for men. No illiterate was encountered during this survey in all the study settlements, so we assume that the level of illiteracy in the area is negligible. Access to education facilities, especially for primary education is very easy in terms of distance to be covered.

The proximity to educational institutions funded by both private and public in all the settlements in this study makes the achievement of goal 2: Universal Basic Education of the Millennium Development Goals (MDGs) possible for these communities.

Energy and Electricity Energy demand in the study area is for lighting, cooking, maintenance workshop and driving machines, (including automobile). Vehicles are driven with gasoline and diesel, electricity and kerosene are used in lighting, while wood, kerosene and liquefied petroleum gas (LPG) are used in cooking. Our experience during the field work is that all these energy types are in short supply. Electric light is epileptic and there are occasions when they receive only a few hours of it in a week. The petroleum based types are scarce and expensive, for instance, one litre of kerosene costs N200 as against the advertised and regulated price of N50. A modest bundle of wood cost N1,000 because the bushes from where they are sourced have been significantly depleted. It is true to say that residents of Agbonchia, Aleto, Akpajo and Elelenwo are facing energy crisis although they sit on huge reserve of petroleum like their other kinsmen in the Niger delta. The energy profile in the study communities is illustrated in Tables 4.10.5and 4.10.6 by NDDC (2008). Table 4.10.5: Percentage Distribution of Household Sources of Fuel for Lighting LGA Kerosene Gas Electricity Generator Battery Obio/Akpor 11.8 1.2 78.8 1.2 0.0 Eleme 94.9 3.0 2.4 0.0 0.0 Source: NDDC (2008)

Table 4.10.6: Percentage Distribution of Sources of Cooking Fuel to Household LGA Wood Charcoal Kerosene Gas Electricity Other Eleme 69.7 0.0 23.2 6.1 1.0 0.0 Obio/Akpor 14.7 2.4 54.1 28.2 0.0 0.6 Source: NDDC (2008)

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Additional sources of energy used in lighting and cooking provided by NDDC include candle charcoal and generator. Personal power generating sets are a ‘’must-have’’ in most Nigerian households indicating that they owned a generator. The primary purpose for owning a generator is to power household appliances and to light up the house. As is well known, public power supply across Nigeria is highly irregular and unreliable.

Housing and Household Possessions Most respondents live in owner occupier houses. Majority of the houses are constructed with concrete blocks and roofed with corrugated iron sheets (73 %). Other types of houses reported by respondents are concrete blocks roofed with asbestos (11.6%), earth block and iron sheets (11.6), and the traditional wattle and mud houses roofed with thatch or iron sheets (3.2%). The crowding index is 1.2, that is, a room is available to every 1.2 persons in the study area. Crowding index that approaches 4 is regarded too high in planning.

Household assets indicated by the respondents include bicycles, motor car, van, television, power generator, motor cycle, radio refrigerator and air conditioner. The most widely owned household possessions are television, generators, and radio sets. Half of the households surveyed in this study owned refrigerators and a third owned car and motor cycle.

Community Health and Health Facilities Agbonchia and Elelenwo have government run health centres. There are many private clinics in all the study communities too. In Rivers State, infants, the elderly over 60 years and pregnant women enjoy free health care in government owned hospitals. Other groups in the population pay for medical services where available or patronise private hospitals. This makes access to medical care difficult for most people in the study communities. The situation is worsened by the low income level where majority of households in the study communities live below poverty level. Eleme Petrochemical operates a well-equipped in- house clinic for people employed.

Most people who need medical attention in the community resort to patent medical store owners for advice or to alternative medicine. Alternative medicine in the study area is very diverse. In Elelenwo for instance, there is specialization in this form of healing. There are practitioners specializing in orthopaedic (NbadiweAmadi and MgbualuEhoro), ear and eye (Chief Ihianyi), paediatrics (EbuchiMgbamosu) remedies against snake bites (Ejekwu James) and epilepsy (ChikweleNjo). Similar specialization was cited by the panel on focus group in Agbonchia, for instance ChinwiOkparaji and Ada Wachi are bone healers in that community.

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Africans attribute most illness to the supernatural and the prayers of their detractors. Some churches belief they can tackle such problems, so it is not unusual for churches to serve as spiritual healing homes, with the promise of cure as sure as orthodox medicine. Healing homes appeal to the mindset of the common man, and the other attraction is that it is cheap and almost free. They nevertheless provide the succour patients crave. There are healers whose talents are not entirely predicated on beliefs. They use herbs and psychology in their approach, an example is Inapow in Aleto.

Traditional birth attendants are also well patronised in the study area. Recently NGOs and government outreach have been educating practitioners on how to improve on their knowledge and make referrals if faced with cases that are beyond their competence.

Cultural Calendar and Social Affiliations Four activities dominate the cultural calendar of communities in the study area namely; wrestling, traditional marriages, new yam festival and dances. Wrestling takes place during and after harvest, usually in the months of September, October and November. Wrestling is invitational that is one community goes to another community, showcases their prowess and engages their host wrestlers in a duel. A winner emerges between two wrestlers when an opponent is dusted on the ground. A visiting community becomes a host to their previous host another.

Marriage is like a rite of passage in the communities. Every adult (males in particular) must marry sometime in their life to signify that they are now men. Marriage ceremonies are however conducted according to the woman’s (bride’s) culture. Traditional marriages in Eleme and Ikwerre are elaborate systems that include hosting the family and community in feasts. As a result, the drinks and foods are the key expenditures the groom has to prepare for. Marriage in these cultures is also not a onetime event among the Ikwerres, this may include a minimum of four occasions and each of those occasions is embellished with food and drinks. In Eleme a woman may be sponsored in what is called Mgbete that takes a year of preparation before her outing to the public and suitors.

The decline in yam production in the area has affected new yam festivals also. New yam festival used to hold in August and it is practiced in all the study settlements. The principle is that nobody in a community eats of their yam harvest unless it is first offered to the gods and ancestors, whom it is believed made the harvest possible. Some respondents who do not grow yam of their own even purchase newly harvested yam in order to partake in the

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IEFCL Train2 Fertilizer EIA Report ceremony. Again the new yam festival which was highly regarded as Christmas today is fading into obscurity due to urbanisation and modernity.

Traditional dances are found in every African culture. The dances may be for members’ only, free and open participation with or without masquerades. The dances may be mixed or gender restrictive sometimes too; Esomba dance in Aleto is for women only. Similarly, Ndudu is a form of dance for women in Ikwerre culture.

Social Affiliation in the societies involves being a member of groups where people share things in common. The categories posed to the respondents include politics, co-operatives, social clubs, education, religion and cultural associations. Across the study communities, affiliation to a religious body was the greatest indicated by the respondents. The implication is that almost all the respondents are religious, usually of the Christian faiths. Affiliation to one or more (mainly foreign) football clubs came second. There is no doubt that most adolescents and young adults in the community have their favourite football clubs, and that watching their club play on television is perhaps their preferred pastime. Other social affiliations include membership of political parties, social clubs, educational associations, co- operatives and cultural clubs. We observed a tendency among respondents to see specialized training in trades like fitting, iron bending, welding and mechanics which are required in striving petroleum industries around the area. Some even enroll for higher education as reasons for citing education as a social affiliation.

Taboos and Sacred Places All human activities in traditional Eleme or Ikwerre setting has a spiritual side to it that is effected through rituals and sacrifices and the places designated to perform these rituals are sacred places. The basic structure of traditional religion in the study areas begins with the family alters. In Agbonchia the study team were shown spots where the family alters are. The Elelenwo people also have their rukannis that approximates the same thing in Ikwerre land.

At the community level there are shrines dedicated to so many causes. Adooka shrine in Aleto protects the community and in Elelenwo Mini Achara will be the equivalent. Seseiokulu in Agbonchia is a shrine to which sacrifices are made before planting, soil fertility and harvest. When things considered abomination (e.g., the death of a woman under pregnancy, drowning) occur, the chief priest Onnenkike in Eleme is invited to cleanse the land through sacrifice, so that such bad event do not happen again. In Elelenwo, an infant who is afflicted may be taken to the shrine of Mini Achara vows made to the deity. If reprieve is granted the parents are expected to redeem their pledge through sacrifice. In

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Ikwerre calendar as used in Elelenwo there are five days in a week namely Riabo, Sarabo, Namake, Okwa and Nim. Riabo is the sacred day in which most traditional religious rites are performed and Nim is the market day. In Eleme there are five (5) days a week namely Obo (big market day), Nma, Ojua, Ochun (small market day), Okor. Obon is the traditional market day that no farming is allowed.

Religion In spite of the traditional observances in the study communities most respondents profess themselves to be Christians. The religious learning of the people include all possible denomination, whether Orthodox or unorthodox. Among the orthodox churches cited are Anglican, Catholic, Lutheran, Baptist, Jehovah’s Witness, and Cherubim. The Anglican Church was however described as the community church. It is usually the oldest Christian denomination in the communities, built through community effort and it will have a mission school attached which isto the congregations commitment. Every community surveyed in this study had several Anglican churches for instance Agbonchia had 4, Aleto 3 and Elelenwo 4. The new (Pentecostals) churches are also gaining acceptance in the communities and their membership is growing even more rapidly. Some of the Pentecostals in the communities include Redeemed, Deeper life, Assemblies, Church of God, Commonwealth and Greater. The attraction of the Pentecostals is in their use of music and rigorous preaching. The congregations are often smaller and the pastors appear to be more likely to be rigid in the interpretation of the doctrines as with Deeper Life, but some are also lax in the area of dressing by not requiring women to cover their head like Winners.90% of the population are Christians, 6% traditional worshiper and 4% Muslims

Conflict Management Dispute over land boundary and ownership is the primary cause of intra and inter communal conflicts in the study settlements. The respondents affirm that there is a rise in conflict over land and who benefits from the proceeds of land in all the study settlements. In relation to the Eleme petrochemical complex, factions of the landlords are already in court to determine the degree of ownership of the property. Settlements like Akpajo with large water front also have disputes over the ownership of water bodies. Politics have become an important source of dispute since the advent of democracy in 1999. Who represents the people at the various levels of government and legislative bodies are becoming contentious because there appear to be a lot to be gained in holding political office. The sources of conflicts among respondents in the study communities are presented in Figure4.10.5

Traditional dispute resolution takes the form arbitration of chiefs acting individually or in a group (in-council). Resort to courts is very popular and was rated by respondents as the

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IEFCL Train2 Fertilizer EIA Report principal mode of dispute resolution. The opening of courts at local government levels has made this option attractive among litigants. In the past it was also usual for people to be summoned before shrines.

4.11 Health Impact Assessment This section presents the baseline health data based on information generated from sampled groups in the study communities. The data relies on self-reporting, presumptions by respondents in the survey and data from the health centers in the area. Data obtained from these facilities were subsequently compared with state and National data and averages that are available.

4.11.2 Health services From the result of the analysis of questionnaire responses, focus group discussion interviews and personal observations, it is apparent that the primary health care delivery service in these communities was inadequate. Healthcare delivery services lack infrastructural facilities, adequate funding for drug procurement, adequate health personnel and financial resources to sustain and upgrade the entire health system.

Health-care facilities The communities of Agbonchia, Aleto, Akpajo and Elelenwo are blessed with primary Healthcare Services Centre, newly built by the Rivers state Government. It is believed that when they will be fully equipped, people in the host communities would have a better opportunity to assess primary health care services. There are however a lot of private clinics, maternities, medical laboratories and pharmaceutical/chemist shops. Some of these health facilities include: 1. Primary Health Care Centers 2. Private medical clinics and Maternities.

In the communities the medical team identified many traditional medicine practitioners, few Traditional Birth attendants who in their limited capacity still assist and compliment orthodox Healthcare delivery. These people lack adequate training in Hygienic procedures. There is urgent need to train them in the area of hygiene to make their contributions more meaningful. There were many patent medicine stores that stock both fake and adulterated drugs, surprisingly at prices beyond the reach of the people. Facilities for prompt/emergency responses were absent only available in few of the hospitals such as the General hospital Eleme etc. Poor economic and financial resources, problem of trained personnel, lack of infrastructural facilities limited the quality and type of Healthcare delivery in these private Health institutions. In these places all the private Healthcare Centres were lacking in

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IEFCL Train2 Fertilizer EIA Report essential equipment and drugs. Laboratory equipment’s were lacking and, where present, were both obsolete and non-functional.

Facilities Available in Communities Table 4.11.1: Health facilities available in the different communities. P Health Private Communities G Hospital Traditional Centre clinic Aleto x √ √ √ Akpajo x √ √ √ Agbonchia x x √ √ Elelenwo x √ √ √ √Presence, XAbsence.

Utilization of Primary Health Services. The table illustration in percentage is the attendance at health facilities in Eleme

Table 4.11.2: Treatment Facility Utilization in Eleme (Agbonchia) S/no Facility Utilization (%) 1. Hospital/Health centre 55% 2. Chemists/Pharmacy 20% 3. Traditional/Herbal home 10% 4 Healing Home/church 15% Source: Field Studies

Surprisingly the use of clinics for birth delivery is relatively low. Patients prefer to go to traditional medical practitioners, churches and untrained traditional birth attendants. The reasons are many and varied according to our informants. Some of the reasons include but not limited to a) High cost of hospital treatment b) Some hospitals are not user-friendly c) Massive, aggressive and vigorous campaigns by the Pentecostal sect that their members will deliver like Hebrew women of the Old Testament without recourse to caesarean section/assisted delivery. The patients come back to the hospital when there are problems/complications such as prolonged/traumatic labour, due to pelvic insufficiency, or cases of breach. There could also be obstetrics pelvic infections due to actions/inactions of birth attendants and pregnant mothers during pregnancy and labour/vaginal examinations,

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IEFCL Train2 Fertilizer EIA Report use of unsterile gloves or taking deliveries in an unhygienic conditions/environment can lead to pelvic infections seen in puerperal sepsis which could lead to infertility and death. Obstetric pelvic infection is almost always a result of intervention during labour or delivery. Poor hygienic conditions and non-observance of aseptic procedures at places of delivery in maternity homes, traditional and alternative settings outside orthodox facilities are important factors.

4.11.3 Nutritional Status The nutritional status was good because of the availability of fish and fish products, and other sea foods which supplied proteins, vitamins and other mineral salts, the people engage in farming and rich calorie foods like yams, garri, rice, corn were produced from their farms. To determine the nutritional status of the people we had to look at background histories and nutritional parameters which are determined by.

 Anthropometry measures, or assessment – height, weight, skin fold thickness arm muscle circumference and other parameters.  Biochemical (laboratory) assessment of blood and urine, enzyme activities, levels of nutrient or the bye-products.  Clinical assessment (physical examination): general appearance of skin, eyes and tongue rapid hair loss, sense of touch, ability to walk.  Diet History: usual intake or record of previous day’s meal.

For the purpose of this study anthropometric assessment was done on children from the different communities i.e. Height, Weight and Mid arm circumference measurements were taken in addition physical examination in general, appearance of skin, eyes and tongue were done. The result of these assessments indicates that the nutritional status was good. There were a few of the children in some of the communities and pregnant women that showed slight evidence of malnutrition, the rest were nutritionally healthy.

Food hygiene The level of food hygiene in the community was low right from collection/marketing of the food items through handling, preparation and service. The Abattoir/slaughter along the East- West highway at Aleto Bridge (Plate 4.11.2) and the one in Elelenwo are both dirty. Environmental health problems arising from poor standard of food hygiene can be alleviated through education and effective health education. Food is often contaminated by exposure during marketing, preparation and serving. The channels of contaminations can be removed by good rural marketing practice and improved personal hygiene.

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Sanitation of the Living Environment The general sanitary status of the living environments in the communities were rated as good based on a set of WHO criteria. Majority of the communities had good sanitary status of the living environments.

Housing Conditions Housing is a fundamental component of quality of life influencing health, sanitation, social environment and community wellbeing. Few of the houses are still roofed with thatches. Most of the inhabitants live in a standard houses as the building has access to improved drinking water. No doubt, the observed housing standard could be assumed to be a vivid reflection of the households’ income level and the challenge posed by the environment in the study area. Housing is a key component in the protection and promotion of health which carries equal priority with nutrition, water supply, sanitation and health care. House needs to be sited properly and constructed in such a way as to provide the physical and social needs of those housed. House needs to protect people from adverse effects of the climate as well as provide fresh air, security and privacy to ensure, dignity, health and wellbeing. All these qualities and attributes depict a good housing in most of these communities.

4.11.4 Reproductive Health Reproductive sexual health services: Reproduction and sexual health as a concept encompasses a set of health problems or diseases associated with the physical and social risks of human sexuality and reproduction.

Common Reproductive and Sexual Health problems in the Communities include.  Lack of access to good quality contraceptive and safe abortion  Hazardous birthing environment  Infertility  Maternal and child malnutrition and infection  Human immune deficiency syndrome (HIV) and sexually transmitted diseases (STIs)

During the sampling, it was found that these health problems exert an enormously heavy illness burden on adults, young people and children, often with long term physical and social consequences. About 50-100 pregnancy related deaths cases occur each year and each of

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IEFCL Train2 Fertilizer EIA Report these perhaps one-quarter to one-third are due to lack of access to safe abortion services. This information cannot be authenticated, because the source could not back it with records. Pregnancy related deaths are only a tip of the iceberg, it is estimated that for every such death, some may have suffered significant complications. In other words many women suffer serious morbidity each year. Of the prenatal deaths among children in the community, about half are associated with low birth weight (under 2500gm) due predominantly to maternal protein-calorie malnutrition and anemia and in some cases STIs. HIV and STIs constitute another major cluster of reproductive health problem, which cannot be statistically reported because of lack of records in the area. Again the State Governments policy/programme in health care may bring succour to this important global issue when the health centres become functional and operational.

4.11.5 Disease prevalence The information provided in these sections is based on hospital records and responses from questionnaires, focus group discussion, on the spot observation and key informants on the nature and pattern of diseases in the communities in the study area in the last 12 months. There were a few fragmented data from hospital records in the area. The prevalence rate (i.e. the number of cases of the condition at a particular time or period divided by the size of the population exposed) has been used in the assessment of disease prevalence. It has enabled a fair interpretation of data about the disease prevalence in the community and it’s comparison with the ill health in other areas in subsequent studies. A reliable prevalence rate could not be determined because of insufficient data In addition a lot of people carried out self-medication while some are treated by traditional medical practitioners and traditional birth attendants without records.

Summary of prevalence of communicable diseases in the community in the projectarea

Malaria Malaria was the most prevalent and occurring disease in the communities hosting the project. It was characterized by periodic chills and fever, its presence is confirmed by examination of blood smear for the parasite. Its prevalent rate was high in the communities in the project area. The high prevalence rate of malaria is sustained by a number of factors:

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 The abundance of mosquitoes (the insect vector of the causative agent which consists of plasmodium falciparium and less of plasmodium vivax and plasmodium malariae),  Presence of stagnant water,  Absence of pest control,  Inadequate prophylactic drugs supply and inadequate diagnostic facility andpersonal indifference to health care.

It affected both male and female of all ages but least in children under one year old. The prevalence rate was high between April and June when the presence of numerous water holding ponds favoured the breeding of mosquito vector. Severity of malaria varies from weakening effect or fever to death particularly in children.

Diarrhoea Diarrhoea was the second most prevalent disease. Its symptom includes unusually frequent passage of loose watery stool and occasional presence of blood pus and mucus in the stool. Protozoa, entamoebe histolytic organisms or parasitic bacteria Escherichia coli cause it. It resulted in severe dehydration and weakness and was prevalent in all the communities of the project area. Its prevalent rate could not be determined due to absence of record. Its high prevalence was attributed to poor sanitation, consumption of facially contaminated water in the community. It affected male and female of all ages but least in children under one year of age; probably as a result of improved maternal care of babies through breast feeding and sterilization of baby food and materials (proper hygiene).

Upper Respiratory Tract Infections This includes any of the several diseases of the respiratory tracts characterized by inflammation of the lungs and caused by bacteria, viruses or chemical irritant. It was prevalent in the communities of the project area. Its severity varies from mild respiratory discomfort to death. It affected both male and females.

Skin Rashes The condition includes measles, chicken pox, ring worm, eczema, different agents caused these. They were generally of medium to high prevalence.

Sexually Transmitted Infections (STIs)

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They include gonorrhoea, acquired immune deficiency syndrome (AIDS). Syphilis and tuberculosis. STIs are important because of the high morbidity and complication, for example infertility, congenital infection and pelvic inflammatory disease (PID), AIDS is now a pandemic health outcome especially in the poor developing countries. Its incidence was high and recorded in many of the hospitals and health centres but was referred to UPTH, BMH and other specialized hospitals probably because of absence and low health facilities and usage. The presence of many seamen and sailors that arrive Onne port many workers working in the over 100 companies in and around Eleme and Elelenwo contribute to the problem.

HIV/AIDS and STIs Control  Forcing prostitutes to get regular examination and treatment  Better treatment to prevent the spread of resistant organism  Good prophylactic drugs.  Immunization against gonorrhoea, it is still at the trial stage.  Examination and treatment of bar girls and other high risk groups.  Utilization of special of STI health visitors or assistants based on wards in towns.  Use of posters.  Telling people to get contacts treated or giving contact slip  Radio announcement about high prevalence  Advising people on early symptoms and having more clinics which are more private and confidential in their management of the diseases.  NGO’s may be required to enhance Health education for secondary schools, youth groups, the communities, and other risk groups.

Schistosomiasis The incidence of Schistosomiasis was very low being lower than 10/10,000 in the area. However it occurred but it is usually mistaken for signs of puberty and in some cases witchcraft.

Filariasis The condition was of high prevalence. Many cases were sighted and this was in agreement with official hospital records.

Tuberculosis The incidence of Tuberculosis was noted in two communities (Agbonchia and Elelenwo) The people involved were physically and clinically examined and there were overt signs of Tuberculosis. In one particular cases the sputum of the patient contained blood in it, and the

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IEFCL Train2 Fertilizer EIA Report patient looking weak and wasted. Con-infection with HIV/AIDS was suspected because the symptoms of both diseases are similar. During the FGD, the people also complained that TB which was hitherto unknown in their communities is now rampant. It was also noted that in some place, people lived in over-crowed houses which certainly predispose people to Tuberculosis as the diseases is airborne.

Tetanus This is caused by mycobacterium tetani. This results from dirty wounds caused by fishing gears and stumps from the farm.

Non-Communicable Diseases Food Poisoning This was recorded only sporadically in the area as resulting from consumption of contaminated food. It caused vomiting, dehydration and body weakness.

Malnutrition It is due to inadequate food intake or micro nutrient deficiency. Only in some parts of the community where the cases were recorded recently and where some children and few pregnant mothers presented with malnutrition. The pregnant mothers equally presented with oedema.

Injury Occupational injuries occurred at the farms and while fishing and from fishing gears. Injuries are also sustained during fetching of fire wood, cutting of wood in the forest, building of boats, boat mishap and fire incident caused by fuel stored in the boats. Some other people get injuries from working in the numerous companies in Eleme e.g. during Tank cleaning and loading and offloading of scrap metals and demolition wastes.

Mental Disorder There were few cases of mental disorder probably caused by substance abuse. Substance abuse is gradually becoming so much of problem in the communities that laws banning the use of substance in the public should be enacted. Punishment should range from fines to ostracism. Substance abuse involves the use of marijuana, heroin and inhalation of poisonous chemicals.

Muscular - Skeletal Disorder

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This condition described as rheumatism was common in the communities. Its prevalence rate was high in the community especially in adult over 50years of age. It manifested as rheumatic pains. It could be as a result of long standing during fishing and other manual works.

Hypertension The blood pressures of the people in the project were determined using the blood pressure monitor (Sphygmomanometer). The prevalent rate of hypertension (blood pressure which exceeded 140/100mmttg) was high. The data showed that many people had blood pressures higher than 140/100. The people were randomly selected from the communities. The specific prevalent rate could not be determined due to insufficient data or records. It occurred more in adult men over 50 years of age. The hypertensive individuals complained of stress from economic hardship and family responsibilities. Hypertensive cases were more among adult males than in adult females of the same age. Juvenile hypertension was not recorded in any of the communities assessed.

4.11.6 Environmental Health Conditions The noise and vibration levels from trucks traffics and aerial one are still within acceptable limits. Treated municipal water was not observed in the communities. Water for drinking and domestics services was streams, hand dug wells, mono pumps, rain harvesting small pools and ponds. Water samples obtained from these ponds, pools had high coli forms counts higher than values recommended by Word Health Organization (WHO), Federal Ministry of Environment (FMENV) for drinking water.

Environmental Conditions in the Community of the Study Area: The entries in this section were compiled from field observation, questionnaire and interviews.

Water Supply There was no Municipal treatment scheme sighted anywhere in the city. Source of water supply included shallow hand–dug well, rivers, streams, ponds, rain harvesting, and a few sometimes non-functional bore holes.There are a few boreholes by SPDC andIEPL, that are used for all domestic purposes including drinking and bathing and the water is not treated before use. As already stated samples of the water analysed in the laboratory showed high coli form count, higher than the values recommended by WHO and Federal Ministry of Environment.

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The pollution of natural and artificial waters in the project area by waste matter resulting from the industrial and human activities, such as slaughter slabs by rivers, dredging and illegal sand mining, are sources of river water pollution in the area. In detail, the main sources of pollution can be considered:  Domestic sewage with high concentration of microorganisms, BOD, organic and inorganic and floatable matter,  Pesticides and fungicides,  Oil & grease and oil dispersants from thousands of tanker trucks in the area. Agbonchia, Aleto, Elelenwo, Akpajo need adequate safe, portable water supply, easy access is a major factor in raising the health standard of the people and its beneficial effect in the reduction of morbidity, especially among children and infants have been established.

Refuse Disposal There was no organized and managed waste management system. In the study areaeach household provides containers to collect the wastes mainly household/organic wastes. Commercial wastes (papers, cartons, nylon bags) and canteen wastes (left-over foods yams and cassava peelings, cans, plastic containers) are usually taken to waste dumps scattered all over the place in Agbonchia, Aleto, Akpajo and Elelenwo. The problem of waste management in the project area as in the case of Nigeria in general is a long term challenge that has become a huge concern for Nigerian cities and rural areas alike(Longe, E.O et a.l2009). Waste management which is constitutionally the responsibility of local governments has been taken over by the state government. This is understandably so because as the local governments have proved their inability to handle the overwhelming challenge of waste management in all areas of the country.

Sewage Disposal In the communities, there are generally little control over the disposal of both liquid and solid waste from industrial, dwellings, villages, factories, towns and cities. As described in the paragraph 4.3.11, the control of the disposal of wastes of all kinds is necessary in order to improve and safeguard public health and to protect water resources.

Disease vectors The vectors identified in the area include:  Mosquito (particularly anopheles species and culex species) were abundant in the area especially in stagnant waters, drains, and in swamps where they breed. They transmit plasmodium which causes malaria.

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 Tsetse fly (glossino species) transmits trypanosome which causes sleeping sickness in humans.  House Fly (Muscadomestica) and latrine fly (fanniacanicularis) were common in refuse dump. They transmitted a wild array of disease agents including those of diarrhoea and dysentery.  Snails occurred in the swamps and are host of shistosoma (s.haematobium and s.mansoni), that causes shistosomiasischaracterised by frequent painful and bloody urination and blood in the stool respectively.

4.11.7 Health Needs of the Community The needs of the community as regards good health include:  Uninterrupted sources of potable water as well as improved and accessible health care facilities;  Training of health manpower (i.e. community health workers (CHEW),nurses, doctors, medical lab scientist, occupational health therapies radiographer and radiologist);  Training traditional birth attendants and traditional medical practitioner on hygienic procedures;  Regular Immunization Programs, provision of facility for prompt/emergency response such as ambulance, mobile clinics;  Monitoring and surveillance for early detection of epidemics;  Health insurance schemes to make health care accessible and affordable to the people.

4.11.8 Corporate Health and Social Responsiveness The present report also reviewed how the proponent had responded to the social and health needs of the host communities.

Sustainable Programs in Host Communities In the past ten years the companies have executed many community development programmes such as building of schools, construction of roads and drainages, rehabilitation of hospitals and supply of medical equipment and electrification projects. Others includes award of scholarships to indigent undergraduates from Eleme and Elelenwo, employment opportunities for indigenes, sponsorship of worthy events, donation of drugs and food items to some charity organizations in the area and youth empowerment programmes. Most of the recent project include building of a massive secondary school complex for Aleto community commissioned and handed over 11th January 2017. Donation of 79 sets of solid high quality seat-fitted tables to the Nigerian Navy basic training school Onne.

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Indorama recognizes the fact that health is wealth and therefore contributes to the medical wellbeing of the people. In September 2011, it carried out a full renovation of the Nchia General Hospital Eleme and donated drugs and medical equipment worth Eighty Million (80,000,000) naira to the hospital. As a follow up medical, Indorama organized a two day eye camp in which about 500 person with eye diseases were treated free of charge.

Indorama CSR project also include the donation of 530,000,000 million in July 2015 for the rehabilitation of the Eleme – Onne Federal highway which had become impassable and coordinated by Rivers State government. The biggest of Indorama CSR programmes is the allotment of 7.5% equity shares of the company to the six (6) host community

Education IEPL has awarded scholarships to 30 students doing engineering program and other science related courses in universities and polytechnics. For Engineering Courses it is for 5 years. Other Science disciplines, it is for 4 years and 2 years for polytechnic students but can be rolled over if the student is immediately admitted for HND upon completion of OND which brings it to 4 years as well. In 2008, the company did a graduate training program for host community engineering student with zero experience and later absorbed them as staff benefited from this programme. The company shall consider it again as personnel requirement improves. The company has purchased a plot of land in Aleto community for the construction of host community ICT and Skill Acquisition Center, which is operational and functional now. In addition to the ICT center, in the past ten (10) years, IEPL has built schools in the host communities, (Massive secondary school complex in Aleto), supplied 79 solid high quality, seat fitted table to the Nigerian Navy Basic Training school in Onne Eleme and awarded scholarship to indigent undergraduate from Elelenwo and Eleme.

Infrastructure The company has done quite enormous number of developmental projects in the host communities building of roads in Elelenwo and Agbonchia communities, electrification project in Njuru and Akpajo communities, building of modern secondary school in Aleto community. The Nchia general hospital has been refurbished with equipments, building of doctors and nurses quarters, building of emergency exit road and major entrance road into the hospital. All these have been commissioned. 2 Floor 12 classroom block is being constructed to be used as a community Secondary School. In each Community the company has expended N26M (N52M for 2 Communities). Each community has 600 MTR road and

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Electrification project consisting of erection of 36 High Tension Poles, 22 Low Tension Poles to cover 1KM, Installation of 1KM long HT and LT Cables and procurement & installation of 500KVA Transformer to power the HT/LT Cables.

Indorama Eleme Petrochemicals Ltd and its sister companies in Port Harcourt have made lives better to its host and transit community as well as the larger society through its numerous corporate social responsibility (CRS) or Corporate Social Investment (CSI) initiatives (Indorama Impact, January – April 2017)

Out Sourcing Lots of contract jobs have been given to host community contractors ranging from civil, electrical, logistics, labour supplies, car hire, equipment leasing, asphalting of roads in the complex, security on the company pipelines etc. IEPL has created a pool of entrepreneurs from the host communities. Capacity of a people to earn income and generate employment been developed.

Conclusively, Appendix 4.11 has been attached to show full details and status of CSR project to the host community.

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CHAPTER FIVE ASSOCIATED AND POTENTIAL IMPACT EVALUATION

5.1 IMPACT METHODOLOGY This chapter presents the overall assessment of associated and potential environmental and socio-economic impacts of the proposed IEFCL-Train2 fertilizer project within Indorama Complex, Eleme. The associated and potential impact assessment covers all stages of the project. The results of technical studies, together with established facts in relevant literatures, perceptions and evaluations of stakeholders, project characteristics (Chapter Three) and general observations obtained during field data gathering (Chapter Four) were considered in the impact assessments. Due recognition was also given to the stipulated standards of the enabling legislative framework and guidelines for sustainable practices applicable in the Fertilizer manufacturing sector.

Mitigation/Compensation measures to ensure that the Project complies with the above mentioned regulatory standards and guidelines will therefore be enhanced in Chapter Six. In some cases mitigations refer to the implementation of management plans that are described in detail in Chapter Seven.

The methodology adopted in assessing the positive and negative impacts of the proposed project is schematically presented in Figure 5.1.

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Figure 5.1: Approach to Impact Assessment for a sustainable project

Impact Assessment Source References

Project Activity Equator Principles/ Description, Social and Environmental IFC Guidelines including Baseline Data Source Specialist Studies ------Impacts Evaluation Criteria Need of Mitigation (*)/ Character (Adverse, Beneficial) Compensation?

Identify Magnitude (High, Medium, Low) Yes/No Impacts Probability of occurrence (High, For each project Medium, Low) Yes/No phase: project Duration (Long/Medium/Short Term) activities and Yes/No potential/associated Situation (Permanent, Temporary) impacts to Yes/No

ImpactsAssessment Reversibility (Irreversible, Reversible) environmental and Yes/No social components Geographical Extension (Regional, Local, Direct) …

------

, ------Identify necessary:

 Mitigation (*)

 Compensation Measures

& Compensation ImpactsMitigation

Action Plan

(*) Mitigation includes also ameliorations as possible changes to the original engineering design and the adoption of management system/program for the different phases of the project.

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5.2 LIST OF POTENTIAL AND ASSOCIATED IMPACTS Potential and associated impacts were identified and evaluated according to the methodology described in the previous paragraph. The final list of positive/negative impacts of the proposed IEFCL-Train2 Fertilizer project is reported in Table 5.1. For each project phase (from construction to decommissioning), activities that can affect the environmental and social components have been identified, together with potential and associated impacts. Also the Health & Safety issues for workers have been considered. The environmental and social components that are likely to be directly or indirectly affected by each impact are listed, possible significant effects are checked and finally the need and nature of dedicated actions to reduce the expected impacts are identified.

A list of criteria has been used to explain whether a project impact is likely to be significant or not for the associated environmental components. The meaning of terms used (when applicable) to underline the characteristics of the expected impacts referring to different criteria is hereinafter reported: a. Character  Positive: beneficial impact for the components affected;  Negative: detrimental impact for the components affected. b. Geographic Extension  Direct: effects confined to the area directly occupied by the Project;  Local: effects beyond the directly Project occupied area but within the limits of the study area under evaluation for the Project;  Regional: effects extend beyond the study area under evaluation for the Project. c. Duration  Short term: effects will last less than 1 year;  Medium term: effects will last between 1 and 5 years;  Long term: effects will last more than 5 years. d. Magnitude  Low: the effects of an impact will determine a slight variation of the existing component’s conditions;

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 Medium: the predictable effects are considerably beyond the existing typical conditions, but without exceeding the criteria established in the permissible limits or without disturbing the economic, social and biological parameters within the ranges of natural variability or social tolerance;  High: the predictable effects will determine a noticeable variation in the conditions of the affected components (e.g. exceeding of permissible limits, detectable change in socio-economic parameters, etc.). e. Situation:  Permanent: Impact will be continual;  Temporary: effects will be confined to a specific period of time. f. Probability of occurrence:  Low: the impact has little probability of occurrence;  Medium: the impact is possible or likely to occur;  High: the impact is (almost) certain. g. Reversibility:  Reversible: effects of the impact can be reversed to the existing typical conditions;  Irreversible: effects of the impact will be continual.

A more detailed discussion on the expected quality of the environmental and social components likely to be affected by the realization of the project can be found in following paragraph 5.3.

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Table 5.1: List of Associated and Potential Impacts of Proposed Fertilizer Project in IEFCL facility

Environmental Needs Project Activities/ Is this likely to result Nature of Potential and and Social dedicated Project Phase Environmental in a Significant effect? Action Associated Impacts Component actions? 1 Aspects Yes/No? – Why? (MI,CO) affected Yes/No? Employment of local Yes, positive impact with labor and award of Socio-economic local effects on medium No - contracts to members of condition term the host communities Yes, negative impact Inter and intra Socio-economic with local effects on Yes MI community conflicts condition medium term

Increased cash flow and Yes, positive impact with stimulation of local Socio-economic 2 local effects on medium Yes CO Recruitment for economies within the condition CONSTRUCTION term construction phase Host Communities Localized economic Yes, positive impact with benefits from materials Socio-economic 3 local effects on medium Yes MI+CO supplies by local condition term contractors Yes, only for health Influx of workers into the 3 conditions . Low host Communities Socio-economic probability of occurrence (including possible condition, Yes MI+CO with possible high increase in Health magnitude and diseases/mortality) irreversible impacts

1 MI = Mitigation CO = Compensation 2 Dedicated actions are foreseen to ensure the expected improvement in socio-economic conditions will be used by the Host Communities in order to obtain an enduring improvement in the existing living conditions. 3 For socio-economic conditions no significant effects are expected (see par. 5.3.10).

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Environmental Needs Project Activities/ Is this likely to result Nature of Potential and and Social dedicated Project Phase Environmental in a Significant effect? Action Associated Impacts Component actions? 1 Aspects Yes/No? – Why? (MI,CO) affected Yes/No? Socio-cultural conflicts Yes, medium probability Recruitment for between the construction Socio-economic of occurrence with Yes MI+CO construction phase team and members of condition possible medium the host communities magnitude local impacts Land Use, Air Quality, Surface Water, Health, Vegetation and Increase in solid/liquid Wildlife, No, see par. 5.3.13 No - waste production Hydrobiology/Se diment, Socio- economic condition Yes, low probability of occurrence with possible Potential increase of negative high magnitude CONSTRUCTION workplace Health Yes MI impacts. Direct effects accidents/diseases All construction with possible irreversible phases consequences Yes, low probability of occurrence with possible Vegetation and negative low magnitude Loss of biodiversity Yes MI Wildlife impact. Direct effects with reversible consequences Yes, negative impact with direct and low Air Quality, Increase in dust, noise magnitude effects. For Noise, Vibration, Yes MI and vibration effects health, low probability of Health occurrence for low magnitude impacts

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Environmental Needs Project Activities/ Is this likely to result Nature of Potential and and Social dedicated Project Phase Environmental in a Significant effect? Action Associated Impacts Component actions? 1 Aspects Yes/No? – Why? (MI,CO) affected Yes/No? Yes, low probability of occurrence with possible Stress on existing high magnitude impact. Health Yes MI security structures Direct effects with possible irreversible All construction consequences phases Soil, Ground Yes, low probability of Risk of spills of Water, Health, occurrence for local, Yes MI hazardous material Hydrobiology/Se negative, medium diment magnitude impacts

Yes, low probability of occurrence for possible Health, Socio- Potential increase of negative high magnitude Mobilization, economic Yes MI+CO traffic accidents impacts. Local effects Transportation of condition with possible irreversible CONSTRUCTION personnel, materials consequences and equipment Air Quality, Yes, negative impact from/to site by road Air/Noise pollution from Noise, Health, with medium term increased vehicular Yes MI Vegetation and duration and with local, movement Wildlife low magnitude effects

Excavation, Soil consolidation and demarcation, Soil Erosion Soil No, see par. 5.3.5 No - foundation laying and pilling

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Environmental Needs Project Activities/ Is this likely to result Nature of Potential and and Social dedicated Project Phase Environmental in a Significant effect? Action Associated Impacts Component actions? 1 Aspects Yes/No? – Why? (MI,CO) affected Yes/No? Employment of local Yes, positive impact with labor and award of Socio-economic local effects on long No - contracts to members of condition term the host communities

Increased cash flow and Yes, positive impact with stimulation of local Socio-economic 4 local effects on long Yes CO Recruitment for economies within the condition term operation phase Host Communities

OPERATIONS Yes, low probability of AND Socio-economic Influx of workers into the occurrence with possible MAINTENANCE condition, Yes MI+CO host Communities medium magnitude and Health irreversible impacts

Air Quality, Land Yes, low probability of Use, Socio- occurrence with possible Routine Operation & Degradation of ambient economic negative medium Maintenance of the air quality for emissions condition, magnitude impacts. Yes MI Fertilizer plants of air pollutants Health, Local effects with Vegetation and reversible Wildlife consequences

4 Dedicated actions are foreseen to ensure the expected improvement in socio-economic conditions will be used by the Host Communities in order to obtain an enduring improvement in the existing living conditions.

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Environmental Needs Project Activities/ Is this likely to result Nature of Potential and and Social dedicated Project Phase Environmental in a Significant effect? Action Associated Impacts Component actions? 1 Aspects Yes/No? – Why? (MI,CO) affected Yes/No? Yes, low probability of occurrence with possible Noise, Health, negative medium 5 Noise annoyance Vegetation and Yes MI magnitude impacts. Local Wildlife effects with reversible consequences

Odor, Health, Yes, low probability of occurrence with possible Land Use, Socio- Odor annoyance negative low magnitude Yes MI economic impacts. Local effects with condition reversible consequences

Water, Land Use, Increase in ground water Socio-economic No, see par. 5.3.4 No - OPERATIONS Routine Operation & consumption AND Maintenance of the condition MAINTENANCE Fertilizer plants Land Use, Air Quality, Surface Water, Health, Increase in solid/liquid Vegetation and Wildlife, No, see par. 5.3.13 No - waste production Hydrobiology/Sedi ment, Socio- economic condition

Landscape, Land Visual Impact of new Use, Socio- No, see par. 5.3.6 No - buildings economic conditions

5 IEFCL is committed to ensure the respect of noise regulatory guidelines and standards. Dedicated study will be drafted. If necessary, noise mitigation measures will be implemented.

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Environmental Needs Project Activities/ Is this likely to result Nature of Potential and and Social dedicated Project Phase Environmental in a Significant effect? Action Associated Impacts Component actions? 1 Aspects Yes/No? – Why? (MI,CO) affected Yes/No? Climate, Land Increase in greenhouse Use, Vegetation and Wildlife, No, see par. 5.3.12 No - gases emissions Hydrobiology/ Sediment

Increase in aqueous Climate, Land No, see par. 5.3.12 No - vapor emissions Use, Vegetation

Increase in emissions of Health No, see par. 5.3.9 No - non-ionizing radiations Soil, Ground Yes, low probability of Risk of spills of Water, Health, occurrence for local, Yes MI hazardous material Hydrobiology/Sedi negative, medium OPERATIONS Routine Operation & ment magnitude impacts AND Maintenance of the MAINTENANCE Fertilizer plants Yes, low probability of occurrence with possible Vegetation and Loss of biodiversity negative low magnitude Yes MI Wildlife impact. Direct effects with reversible consequences

Yes, low probability of Potential increase of occurrence with possible negative high magnitude workplace Health Yes MI impacts. Direct effects with accidents/diseases possible irreversible consequences

Induced secondary Socio-economic Yes, positive impact with 6 Yes MI+CO industrial development condition regional, long term effects

6 Dedicated actions are foreseen to ensure the expected improvement in socio-economic conditions will be used by the Host Communities in order to obtain an enduring improvement in the existing living conditions.

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Environmental Needs Project Activities/ Is this likely to result Nature of Potential and and Social dedicated Project Phase Environmental in a Significant effect? Action Associated Impacts Component actions? 1 Aspects Yes/No? – Why? (MI,CO) affected Yes/No?

Yes, low probability of Health, Socio- occurrence with negative Potential increase of traffic economic high magnitude impacts. Yes MI+CO accidents Mobilization, condition Possible local effects with Transportation of OPERATIONS AND irreversible consequences personnel, materials MAINTENANCE and final products Yes, negative impact with from/to site by road Air/Noise pollution from Air Quality, Noise local effects and low increased vehicular Health, Vegetation Yes MI magnitude. Long term movement and Wildlife duration

Employment of local labor and award of contracts to Socio-economic As per Construction phase No - members of the host condition communities

Increased cash flow and stimulation of local Socio-economic 7 As per Construction phase Yes CO economies within the Host condition Communities Recruitment for DECOMMISSIONING decommissioning phase Localized economic benefits from materials Socio-economic 7 As per Construction phase Yes MI+CO supplies by local condition contractors

Influx of workers into the Host Communities Socio-economic As per Construction phase Yes MI+CO (including possible increase condition, Health in diseases/ mortality)

7 Dedicated actions are foreseen to ensure the expected improvement in socio-economic conditions will be used by the Host Communities in order to obtain an enduring improvement in the existing living conditions.

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Environmental Needs Project Activities/ Is this likely to result Nature of Potential and and Social dedicated Project Phase Environmental in a Significant effect? Action Associated Impacts Component actions? 1 Aspects Yes/No? – Why? (MI,CO) affected Yes/No?

Land Use, Air Quality, Surface Water, Health, Increase in solid/liquid Vegetation and Yes, low probability of Wildlife, occurrence of medium Yes MI waste production Hydrobiology/ magnitude impacts Sediment, Socio- economic condition

Potential increase of workplace Health As per Construction phase Yes MI accidents/diseases

Air Quality, Noise, As per Excavation and All decommissioning Increase in dust, noise Vibration, Health, DECOMMISSIONING Erection of Structures of Yes MI phases Vegetation and and vibration effects Construction phase Wildlife

Soil, Ground Risk of spills of Water, Health, As per Construction phase Yes MI hazardous material Hydrobiology/ Sediment

Stress on existing Health As per Construction phase Yes MI security structures

Vegetation and Loss of biodiversity As per Construction phase Yes MI Wildlife

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Environmental Needs Project Activities/ Is this likely to result Nature of Potential and and Social dedicated Project Phase Environmental in a Significant effect? Action Associated Impacts Component actions? 1 Aspects Yes/No? – Why? (MI,CO) affected Yes/No?

Health, Socio- Potential increase of As per Construction economic Yes MI+CO traffic accidents phase Mobilization, condition Transportation of DECOMMISSIONING personnel, materials and equipment Air Quality, Air/Noise pollution from from/to site by road Noise, Health, As per Construction increased vehicular Yes MI Vegetation and phase movement Wildlife

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5.3 EXPECTED QUALITY OF THE ENVIRONMENTAL AND SOCIAL COMPONENTS AFTER THE IMPLEMENTATION OF THE PROJECT Hereinafter it is provided an evaluation of the expected quality of the environmental and social components after the construction, operation and decommissioning of the proposed IEFCL-Train2 Fertilizer Project. Also Health & Safety topics have been considered. The discussion presented here are intended to provide insight into the nature, magnitude and duration of the impacts on environmental and social components. Impact assessment considered also the predicted adoption of dedicated actions (see Chapter Six and Chapter Seven for details) to ensure the social and environmental compatibility of the project.

5.3.1 Air Quality Gaseous emissions to the atmosphere would be generated both during construction and operation of the proposed IEFCL-Train2 plant. Emissions to air may be gaseous or in the form of particles loaded by adsorbed gases. Gaseous emissions may cause air quality impacts on human health particularly where emissions are of harmful gases. The pollutants releases to air would be either direct physical or by chemical reactions and transformation involving operations, combustion of fuels and transportation as well as packaging and loading of materials.

The dust generation during construction activities is much lower in rainy season and during dry season dust can be controlled by water spraying or other management practices. The emissions are short term and localized to the construction site. During operation the impact on air quality is rated as medium with reversible consequence.

5.3.2 Noise and Vibrations The construction of the proposed IEFCL-Train2 Fertilizer Plant is expected to produce a reasonable amount of noise that will have negative impacts on site workers and other sensitive receptors in the vicinity of the project corridor. Moderate noise impact from operation facilities may be experienced at night. With mitigation measure in place, a

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IEFCL -Train2 Fertilizer Project EIA Report potential moderate short term impact is predicted as a result of construction activities; while operation activities will constitute long-term noise impacts. Thus workers is to be provided with appropriate PPEs, while management encourage shift working system, and other engineering principle to comply with existing Noise limit.

Temporary and occasional impacts on vibrations are expected during the construction phase. Considering the distance between the project site located within Indorama complex premises and receptors, there are no sensible receptors interested by the initiative. For noise and vibrations, workers will be adequately trained and equipped in order to ensure the safety of their activities.

5.3.3 Surface water and Hydrobiology/Sediment The receiving water body (Okulu Stream) hydro chemical and hydro biological/sediment quality, as can be respectively evinced by the baseline description provided in Chapter Four (4), is at present time low and makes such stream not suitable for drinking or other potential human fruition purposes. The main cause of Okulu Stream deteriorated conditions is associated to illegal sand mining and dredging activities.

This is not likely to generate an additional deterioration of surface water and its hydrobiology/sediment because: • compliance with regulatory limits at discharge point will be ensured also after the operation of the new Fertilizer Plant; • The waste water stream from Fertilizer Plant will be in accordance with applicable IFC standards (Environmental, Health, and Safety Guidelines for Nitrogenous Fertilizer Production, par. 2.1, Table 2).

5.3.4 Ground water The new project will determine an increase in ground water consumption from current 1750 m3/h to 2500 m3/h expected. This increment will not affect negatively the ground

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IEFCL -Train2 Fertilizer Project EIA Report water potential recharge rate and ground water flows. The soil of the site show five (5) unit of silty clay, clay, clay sand, fine sand and coarse gravel sand. See attached Borehole logs in Appendix-4.9. This is in agreement with the soils in the Niger Delta area which have natural clay –cap capacity that helps in preventing the percolation of liquids to the aquifer. Also, the favorable particle size distribution of the soil with the clay component comprising two third of the particle distribution and the hydrogeological characteristic of the borehole logs considering the range of key parameters such as porosity, permeability, well discharge rate, water table, flow direction etc. further supports the low rise potential of the ground water contamination in the study area.

Risk of ground water contamination due to accidental spills is minor because:  The entire Project will adopt an Environmental Management System aimed at minimizing any possible accidental event;  The risk of contamination is minimal considering soil characteristics of the area interested by the project (see appendix 4.9).

5.3.5 Soil The fertilizer project is planned to be constructed on a plot of land within the Indorama complex in IEFCL facility, which has been compacted and consolidated. There is no vegetation on the plot of land because the soil engineering carried out on it, in preparation for further use. The absence of vegetation on it indicates poor biota. Consequently baseline stations in terms of soil elements on site will not likely change drastically during construction and operations. All the same construction, operation and decommissioning phases will be implemented in accordance with provisions in the Environmental Management Plan to ensure that changes in baseline conditions are discovered on time and corrective measures implemented. The construction activities will take into account the soil geological and geotechnical characteristics, with particular attention to avoid the execution of construction activities during the wet season in order to exclude possible soil erosion concerns.

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IEFCL -Train2 Fertilizer Project EIA Report

The Project will be located inside industrial areas under the control of IEFCL without using virgin lands. At the end of decommissioning activities terrains will be restored to the existing environmental conditions.

5.3.6 Land Use As previously indicated, the Project does not imply consumption of land use outside the areas under IEFCL control and however will not have impacts on the current land uses in the study area (e.g. agricultural land use). The initiative is in compliance with the existing destination of land uses inside the territory. During construction, operation and decommissioning phases, IEFCL will provide residential houses and temporary buildings within Indorama Complex to allow the sustainability of existing residential uses outside the complex.

5.3.7 Job creation and housing for construction workers The employment during the construction stages will mainly be done by the EPC Contractor. Indorama Eleme Fertilizer & Chemicals Limited (IEFCL) will also carry out recruitment on its roll during the construction and subsequently for the operation phase of the project. The details of projected manpower recruitment are given in the table below:

Employment Unit of 2018 2019 2020 2021 Particulars Measurement

EPC Number 1500 4000 4000 350 Contractor

IEFCL Number 54 200 200 200

All recruitments will be done in compliance to applicable Laws of Federation of Nigeria.

Mitigation measures for transition from construction to operation Important mitigation measures for these workers are as under:

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IEFCL -Train2 Fertilizer Project EIA Report

 Disengagement benefits including end of Contract Bonus.  Some persons will be absorbed in to the system by means of direct jobs depending on skills.  Some persons will be absorbed in to the system by means of other indirect jobs through sub-contracting such as engagement under security / maintenance contracts and other contracts like loading and unloading, housekeeping, material handling including forklift operations, waste disposal etc.

Provision of Residential/Temporary buildings in the complex Proponent would provide residential houses and temporary buildings within and around the project area a) Permanent Buildings There are residential buildings in the Complex for experts – built over an area of 10900 square meters. b) Temporary Buildings The details of temporary buildings during construction phase are tabulated below: No. of S. No. Particulars Total Area (Sq. meter) Buildings 1 Residential Buildings 12 4531 Buildings for other 2 facilities including 6 1324 recreation 3 Canteen 2 950 Site offices, training Hall 4 7 2980 and warehouses Total Area (Square meter) 9785

These buildings will service the requirement for engineering/Technical services

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5.3.8 Vegetation and Wildlife Under Fertilizer Plant operating conditions the initiative will not contribute appreciable amount of air pollutants emissions into the atmosphere likely to negatively affect the existing quality of vegetation around the complex. Moreover, no variation of existing surface water bodies’ quality likely to modify the characteristics of surrounding vegetation is expected.

Wildlife Impacts expected during construction phase will be temporary, time limited and associated to diurnal hours. Current fruition of the existing fauna will not change during all project phases. The project does not foresee the consumption of terrestrial ecosystem unit with the only exception of the industrial use areas inside Indorama complex designated to the realization of the IEFCL- Train2 project.

5.3.9 Health The initiative will have negative health impacts on host communities around Indorama Complex, due to the influx of workers are possible carriers of some communicable diseases. For further considerations on potential impacts that could also produce possible effects on the health of host communities, see also paragraphs 5.3.1 (Air Quality), 5.3.2 (Noise and Vibration), 5.3.3 (Surface water and Hydrobiology/Sediment) and 5.3.4 (Ground water). Concerning waste production, the new wastes produced will be managed according to the existing Management System, by using the existing facilities inside the Complex and by optimizing waste recovery whenever possible.

A population increment by the near host communities associated to the realization of the IEFCL-Train2 Project is expected, in particular during construction phase. This increment will be managed in a proper manner in order to safeguard the health of host communities deriving from possible exposure to infective / transmissible diseases.

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During the construction, operation and decommissioning phases, IEFCL will put in place all the necessary measures to ensure health of workers and environmental safeguard and to minimize the risk of possible incidental events.

During its different phases the project, will also contribute an increase to the existing traffic movements, that will be managed with the purpose of minimizing possible health impacts and the risk of traffic related accidents in the area interested by the project.

In relation to emissions of non-ionizing radiations, minor impacts on human health are expected as a consequence of the present project.

5.3.10 Socio-Economic conditions The project will determine an increment of both direct and indirect employment during all project phases. The host communities will particularly benefit from this expected increment. In this direction it is believed that the population increment will be accepted by the socio-economical context in the host communities. This population increment will be managed by IEFCL by a proper adjustment of the offer in services both inside and outside the industrial complex.

An acceptable increment of vehicular traffic associated to the initiative is also expected and will be adequately managed in order to minimize possible socio-economical impacts. The construction of IEFCL-Trains2 Project is expected to add significantly to existing traffic volume on East-West Expressway which is short-term, while during the operation it is expected to contribute minimally to existing traffic volume. This minor increment may or may not negatively affect the quality of existing road services that is currently under repairs by the Federal Government.

All project phases will be managed, wherever possible, involving local stakeholders to avoid/minimize the generation of possible conflicts. Moreover, there are no socio-economic

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IEFCL -Train2 Fertilizer Project EIA Report activities that are going to be negatively affected by the project and the new installations of IEFCL-Train2 will not interfere with cultural/social elements present in the study area.

The most significant increase in waste production will be temporary and will occur during the construction phase. This increment will not negatively affect the socio-economic conditions existing in the area, since existing IEPL/IEFCL facilities are capable to adequately manage the additional stream of waste that will be generated by the initiative.

5.3.11 Landscape Installation of the new plants will not cause significant variation of the existing landscape features in the study area and will interest only already industrial areas inside Indorama complex. See appendix 3.1 for trial photographical rendering of IEFCL site after the realization of Fertilizer Plant.

5.3.12 Climate Considering the morphological features of the site together with the engineering solutions that will be implemented in the detailed engineering design of the project, the initiative will not modify the existing microclimatic conditions of the site, considering also the expected increment of aqueous vapor emissions in atmosphere from Cooling Towers.

Concerning CO2 emissions, it is worth noticing that the project will use natural gas as raw material, energy resource that is currently unused and largely flared thus contributing to climate change. This initiative is an alternative avenue for utilizing the CO2 resulting from reforming of the natural gas, for the manufacturing of Urea.

5.3.13 Improper Waste Generation In adequate management of food waste from camp site during construction and discharge of untreated effluent into the aquatic system, can trigger eutrophication, which will result to algal bloom as well as zooplankton depleting the dissolved oxygen, and increasing the

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IEFCL -Train2 Fertilizer Project EIA Report biochemical oxygen demand (BOD). Other wastes could raise the toxicity level (heavy metals) of the water. All organisms linked to the food web including fish and man could be affected. The impact is direct, negative, short term, local and reversible. The rating of impact is moderate.

5.3.14 Contamination of surface soil with used lubricant Lubricants used for vehicle, heavy equipment and machinery maintenance could result in the contamination of topsoil, which is expected both during construction and operation, if not properly managed. This impact is considered direct, negative, short term, local, and reversible with a moderate rating.

5.3.15 Stress on Road infrastructure The proposed IEFCL-Train2 Fertilizer Plant during operation will result to traffic situation on East-West Expressway, with associated impacts on public safety, transport and access. The Traffic Management Plant for this project has taking into account background traffic associated with existing traffic volumes and addition of traffic generated by the proposed project. Thus, cumulative impacts on road networks and traffic congestion could have a negative effect on public health and safety. IEFCL can manage traffic impacts from its own activities through implementing Traffic Management Plan and other mitigation measures. However, the responsibility to ensure adequate and safe road infrastructure for industries lies in the hands of the Government. Consequently, IEFCL would support government initiatives, including detailed traffic studies in its area of operation to determine road network capacity, road integrity, safety hazards and problem intersections in relation to its own operations as this will help to achieve a safe and efficient transport system to the benefit of Indorama Group and the general public.

5.4 CUMULATIVE IMPACT ASSESSMENT The proposed IEFCL-Train2 Fertilizer Plant will be sited in the existing Indorama complex, where already IEFCL-Train1 of same project exists in addition to other plants. Therefore

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IEFCL -Train2 Fertilizer Project EIA Report cumulative impact assessment of this IEFCL-Train2 in relation to the existing IEFCL-Train1 is important to ascertain the combined effect of both projects to the valued environmental component (VECs) immediate to this facility in order to proffer mitigation measure. Given the fact that there is an Agency in Nigeria in-charge of Pollution Control, review of the existing Cumulative Impact Assessment report will add IFC Guideline for this assessment which entails:  Definition of spatial and temporal extent of the project  Identification of information requirements  Establishment of project governance  Information gathering  Analysis of cumulative impacts in relation to key environmental factors  Use of both quantitative and qualitative methods  Expert and peer review  Preparation of assessment documentation  Consultation with the public, key stakeholders and regulators

Based on the individual impact assessment for the projects, majority of the cumulative impacts would occur during the operational phase only, as construction is not expected to coincide with any other construction within the Indorama complex. The most of the cumulative effects would occur, when there is an overlap of activities. These activities will be taking place within an area of about 2 km2.

The cumulative positive impacts identified are  Business Opportunity/Economic enhancement  Skills acquisition  Increase in revenue for the Government, Community and Indorama

The cumulative negative impacts identified are:  Increase in cost of living/Inflation

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IEFCL -Train2 Fertilizer Project EIA Report

 Increase in potential for road traffic volume  Increase in noise nuisance  Stress on existing security structures  Changes in local population  Pressure on existing infrastructure and utilities  Increase in communicable diseases (including STIs)  Soil degradation from spills and leaks  Fire and explosions

The significance rating of each of these impacts has been obtained through the process of impact identification, ranking and quantification, in each of the project phases.

5.4.1 Cumulative Positive Impacts . Business Opportunity/Economic enhancement . Skills acquisition . Increase in revenue for the Government, Community & Indorama

5.4.2 Cumulative Negative Impacts

Increase in Road Traffic Volume/ Accidents & Incidents/Noise With construction ongoing at various locations within an area of 2 km2, there would be a cumulative increase in the volume of traffic plying the East-West Expressway as goods, personnel and equipment are being moved into, out and within the area by road. This may also affect other road users and cause traffic hold-up on the road. This also has the potential to cause an increase in road traffic incidents due to dangerous/reckless driving, breakdown of vehicles, pedestrians and other road hazards. There would also be an increase in the noise level especially along the East-West Expressway and close to the various construction locations.

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IEFCL -Train2 Fertilizer Project EIA Report

Increase in Groundwater Extraction Coming on stream of IEFCL-Train2 Fertilizer Project will increase the ground water consumption within the facility, which may affect ground water reservoir. Therefore measure should be taken to recycle and reuse process water as much as to cut down extraction of groundwater from the aquifer.

Population Increase With each influx of construction workers, there would be the attendant increase in camp followers. As the workers for each project would be exclusive to the project it is expected that when the project schedules overlap. This enlarged population has the potential to change the demographic characteristics of the Eleme area.

Increase in the cost of living (inflation) As was observed in other projects (e.g. Bonny NLNG), with each influx of personnel & camp followers for the various projects, there is bound to be a continuous increase in the cost of goods and services, due to an increased demand. This demand would drive competition among the service providers and ensure those businesses with high patronage would be able to increase prices sometimes beyond the limit of the community indigenes, thereby causing inflation. This impact is rated high.

Stress on existing infrastructure & Utilities Though contractors would provide accommodation, feeding, transport etc. for their workers, the camp followers would utilize those services and infrastructure available within the communities. Thus, there would be cumulative stress on the poor infrastructure and utilities with each influx of camp followers.

Increase in communicable diseases With each influx of construction workers & camp followers, the frequency of STIs would increase as well as the chances of individuals contacting different types of infections. The

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IEFCL -Train2 Fertilizer Project EIA Report cumulative effects of different infections in individuals would compromise their health status leading to absence from work, loss of income and, in the extreme case, death.

Water and soil contamination The potential causes for land contamination are the discharge of liquid effluents, disposal of solid and hazardous wastes on land and accidental spillages of hazardous material. Spill of herbicides, pesticides and fertilizers could result in soil contamination. The likelihood and significance of the impact is low. However simultaneous operation activities within the facility will increased potential for accidental spills and leaks that could cause water and soil contamination, which is not expected. With an increase in the frequency of contamination there is the potential for some of the contaminants to accumulate especially in soil and sediments. In addition, vegetation and topsoil removal at various project locations could lead to the deterioration of biota from run-off and siltation.

Chemical spillage There are possibilities that there will be cumulative effects arising from minor multiple spills occurring within the facility over time from different sources. The probability of major spills, particularly those that could affect the immediate environment adversely is expected to be low, given the proactive nature of the existing spill contingency plan ground to take over the situation, if it occurs.

Fires and Explosions: The addition of IEFCL-Train2 Fertilizer Plant in the existing Indorama complex may result to cumulative increase in fire and explosions risk due to the storage of concentrated chemicals for both facilities. As such outmost care must be taken while running the two facilities, to cut down on the possibilities of fire outbreak within the facility.

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IEFCL -Train2 Fertilizer Project EIA Report

CHAPTER SIX MITIGATION, AMELIORATION AND COMPENSATION MEASURES

6.1 INTRODUCTION The measures that IEFCL intend to take to reduce (or eliminate) negative impact and promote positive Environmental and Social impacts of the proposed IEFCL-Train2 Project are presented in this chapter, taking into account also Health and Safety topics. In these measures, emphases are placed on those negative impacts rated as significant. These actions are aimed at reducing these impacts to as low as reasonably possible. The residual impacts that could arise despite these measures were also noted.

MITIGATION MEASURES The associated and potential impacts on various components of the biophysical, health and social environments by the proposed IEFCL- Train2 Fertilizer Project is presented in Chapter Five. The negative impacts have been identified and ranked accordingly.

To preserve the environment and ensure sustainability of this project, a number of steps have been taken to mitigate the significant, medium and high ranking negative impacts identified as a result of the proposed development, as well as enhance those impacts identified as positive.

The mitigation measures proposed for the predicted impacts took cognizance of the following:  IFC Guidelines;  Performance Standards on Social and Environmental Sustainability;  General EHS Guidelines;  Industry Sector Guidelines;  Best Available Technology for sustainable development;  Feasibility of application of the measures in Nigeria;  Concerns and views of stakeholders during extensive consultations conducted during the study, and

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 The residual effects that arise despite the mitigation measures have also been discussed for effective mitigation to a low level.  Environmental laws at national, regional and international levels;

Other Factors considered for determining implementation of measures are:  Avoiding the impacts altogether by not taking a certain action or parts of an action;  Minimizing impacts by limiting the degree or magnitude of the action and its Implementation;  Rectifying the impact by repairing, rehabilitating or restoring the affected Environment;  Compensating for the impact by replacing or providing substitute resources.  Feasibility;  Ease of implementation;  Local suitability;  Institutional requirements;  Training requirements;  Monitoring requirements;  Cost (capital and operating);  Cost-effectiveness.

The Required General and Specific measures, includes:  Pre-construction;  Site Preparation and Construction;  Commissioning and Start-up;  Decommissioning and Abandonment.

The measures are categorized by relevant impact category, potential impact, interested project phase and related nature (mitigation or compensation measures).

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The measures that IEFCL commits to implement for the proposed IEFCL-Train2 Fertilizer project activities likely to determine environmental, socio-economical and/or health impacts are detailed in Table 6.1.

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Table 6.1: Impact mitigation measure Significance Rating Project Significance Type of Description of After Mitigation Phase Project Activity Rating Before Action measure Impact (Residual Impact (C, O, D)1 Mitigation (MI, CO)2 Rating)  According to the MoU (Appendix 6.1), IEFCL will ensure that all host communities are represented in the employment of locals during land clearing and excavation to Recruitment for avert any conflict that could arise construction, Inter and intra from perceptions of unfairness C+O+D operation and communities Medium  IEFCL will ensure the monitoring of MI Low decommissionin conflicts host communities development to g phases identify and minimize possible causes of conflict  IEFCL will adopt a Social Management System to avoid possible inter and intra communities conflicts

1C= Construction O = Operation D = Decommissioning

2MI= Mitigation CO= Compensation

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Significance Rating Project Significance Type of Description of After Mitigation Phase Project Activity Rating Before Action measure Impact (Residual Impact (C, O, D)1 Mitigation (MI, CO)2 Rating)  IEFCL will adopt a Social Management System to avoid possible socio-cultural conflicts between the construction team and members of the host communities. MI  IEFCL will regularly hold Stakeholders Forum with the representatives of the Socio-cultural communities Recruitment for conflicts between construction, the construction  IEFCL will abide by all C+O+D operation and Medium Low team and Memorandums Of Understanding decommissionin members of the (MOUs) signed with the host g phases host communities communities providing: - Building of/arrangements to educational/health facilities; CO - Access to micro credit system and merit scholarships for members of the communities. For more details, see the Stakeholders Management Plan in Appendix 7.2.

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Significance Rating Project Significance Type of Description of After Mitigation Phase Project Activity Rating Before Action measure Impact (Residual Impact (C, O, D)1 Mitigation (MI, CO)2 Rating)

 Health awareness lectures shall be given to workers on the mode of transmission of STIs (including Influx of workers HIV/AIDS) Recruitment for into the host construction, communities  Provision of regular pest control C+O+D operation and (including possible Medium and insecticide in residential and MI Low decommissionin increase in office area inside the complex g phases diseases/ mortality)  In accordance to the Monitoring Program (see Chapter Seven) IEFCL will support for health check-up programme of communities.

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Significance Rating Project Significance Type of Description of After Mitigation Phase Project Activity Rating Before Action measure Impact (Residual Impact (C, O, D)1 Mitigation (MI, CO)2 Rating)  Awareness campaign will be carried out to enlighten the communities/field workers on the common communicable diseases and the health implications of drug and alcohol abuse, unprotected sex, prostitution and the need to sustain cultural values  Alcohol and drug policy shall be implemented to encourage healthy lifestyle for workers  IEFCL will ensure site clinic is MI Low provided to take care of minor illnesses for all construction workers  IEFCL will conduct enlightenment campaign and health education for the abatement of abuse of drugs, alcohol among workers throughout the life of the project  IEFCL will ensure that contractor enforces the alcohol and drug policy for staff

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Significance Rating Project Significance Type of Description of After Mitigation Phase Project Activity Rating Before Action measure Impact (Residual Impact (C, O, D)1 Mitigation (MI, CO)2 Rating)  IEFCL will ensure that contractor implements social and health awareness programs for all workers at induction and on a continuous basis throughout the Influx of workers life of the project Recruitment for into the host  IEFCL will make adequate construction, communities accommodation arrangement for C+O+D operation and (including possible Medium MI Low expatriates prior to mobilization of decommissioni increase in workforce to reduce pressure on ng phases diseases/ local housing. mortality)  IEFCL to ensure that good, and sufficient water supply will be maintained for workers to avoid Waterborne/water-related and water-based diseases.

Influx of workers  In accordance to the Monitoring Recruitment for into the host Program, IEFCL will yearly verify construction, communities the health status into the host C+O+D operation and (including possible Medium communities, in order to identify MI Low decommissionin increase in possible actions to be taken for g phases diseases/ their safeguard in relation to the mortality) expected influx of workers

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Significance Rating Project Significance Type of Description of After Mitigation Phase Project Activity Rating Before Action measure Impact (Residual Impact (C, O, D)1 Mitigation (MI, CO)2 Rating)  IEFCL will assist the activities of the state action committee on STIs/HIV/AIDS within the local communities

 If Authorities will take initiatives CO for provision of potable water to host communities, IEFCL will support projects for the provision of potable water to host communities

 IEFCL will carry out enlightenment campaigns to encourage positive influences on cultural values and Increased cash healthy lifestyles (e.g. breast flow and feeding habits, alcohol and drug stimulation of Medium use, exercise, monogamy, high CO Medium/High3 local economies moral values with regard to within the host sexuality, etc.) and discourage communities adverse influences (e.g. prostitution, drug abuse, alcoholism etc.)

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Significance Rating Project Significance Type of Description of After Mitigation Phase Project Activity Rating Before Action measure Impact (Residual Impact (C, O, D)1 Mitigation (MI, CO)2 Rating)

 In accordance to the Monitoring Program, IEFCL will yearly verify the status of Assisted Projects in Localized order to verify their effectiveness economic benefits Medium and to identify possible actions to MI Recruitment for from material be taken aimed at obtaining an construction, supplies by local enduring improvement in the C+O+D operation and contractors (C+D) existing living conditions inside the Medium/High3 decommissionin and Induced host communities g phases secondary industrial  IEFCL will support skill development (O) development programs CO Medium  IEFCL will support cooperatives and micro-credit schemes (directed in particular to women)

3 Positive Impact

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Significance Rating Project Significance Type of Description of After Mitigation Phase Project Activity Rating Before Action measure Impact (Residual Impact (C, O, D)1 Mitigation (MI, CO)2 Rating)  IEFCL will train its personnel by an Environmental Capacity Building Program for minimizing the environmental impact and risks  In accordance to the Monitoring Program IEFCL will periodically check the initiative in compliance with air quality/noise standards in order to implement dedicated All Increase in actions if necessary construction, solid/liquid waste  In accordance to the Monitoring C+O+D operation and production, dust, Medium Program IEFCL will yearly verify MI Low decommissionin noise and the waste production in order to g phases vibration effects implement dedicated actions if necessary  In accordance to the Monitoring Program IEFCL will verify the characteristics of water discharges and the quality of receiving water body (water and hydrobiology/ sediment quality) in order to implement dedicated actions if necessary

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Significance Rating Project Significance Type of Description of After Mitigation Phase Project Activity Rating Before Action measure Impact (Residual Impact (C, O, D)1 Mitigation (MI, CO)2 Rating)

 In the event that either construction or decommission site activity run into dry season, water will be sprayed on onsite to reduce dust level. All Increase in construction, solid/liquid waste  IEFCL will alert communities in C+O+D operation and production, dust, Medium advance of such activities that are MI Low decommissionin noise and likely to increase noise in the very g phases vibration effects nearby residential houses  IEFCL will ensure that demobilization activities are according to international best practice.

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Significance Rating Project Significance Type of Description of After Mitigation Phase Project Activity Rating Before Action measure Impact (Residual Impact (C, O, D)1 Mitigation (MI, CO)2 Rating)  IEFCL will ensure that a controlled fuelling, maintenance and servicing protocol for construction machinery at worksite is established and followed to minimise leaks and spills  IEFCL will ensure that all maintenance and repair of equipment and vehicles are done All in a secure location with clean-up construction, Risk of spills of materials (e.g. drip pans, C+O+D operation and hazardous Medium MI Low containers, absorbent materials decommissionin materials etc.) readily available g phases  IEFCL will ensure integrating prevention and control measures set in a General Hazardous Materials Management program  In case of environmental contamination IEFCL will ensure that a planned risk management approach will be followed

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Significance Rating Project Significance Type of Description of After Mitigation Phase Project Activity Rating Before Action measure Impact (Residual Impact (C, O, D)1 Mitigation (MI, CO)2 Rating)  IEFCL will ensure a deep characterization of soil after site cleaning, to detect potential historical releases of hazardous material4  IEFCL will train its personnel by an All Environmental Capacity Building construction, Risk of spills of Program for minimizing the Medium C+O+D operation and hazardous environmental impact and risks MI Low

decommissionin materials  In accordance to the Monitoring g phases Program IEFCL will verify the status of ground water quality in order to adopt, if necessary, dedicated actions aimed at minimizing the risk of contamination of ground water from spills of hazardous materials

4For decommissioning phase only

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Significance Rating Project Significance Type of Description of After Mitigation Phase Project Activity Rating Before Action measure Impact (Residual Impact (C, O, D)1 Mitigation (MI, CO)2 Rating)

 IEFCL will implement a Risk management Plan for Contaminated lands in order to identify, if necessary, dedicated actions aimed at minimizing the All risk of land contamination caused construction, Risk of spills of C+O+D Medium by accidental spills of hazardous MI Low operation and hazardous materials decommissionin materials g phases  IEFCL will implement a Hazardous Materials Management Plan to minimize the risk deriving from spills of hazardous materials

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Significance Rating Project Significance Type of Description of After Mitigation Phase Project Activity Rating Before Action measure Impact (Residual Impact (C, O, D)1 Mitigation (MI, CO)2 Rating)

 IEFCL will ensure there are adequately trained numbers of first aiders at each site;

 IEFCL will ensure that safety workshops to identify, evaluate and recommend contingency plans for all security risks are regularly organized All Potential increase  IEFCL will implement an construction, of workplace Occupational Health and Safety C+O+D operation and High MI Medium accidents/ Management Plan (including decommissionin diseases Hazardous Materials Risks g phases Management Plan) to minimize the risk of potential increase of workplace accidents/diseases

 A quantitative Risk Assessment (QRA) of the whole complex will be implemented to verify that the adopted safeguard measures are consistent with the required high level of protection.

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Significance Rating Project Significance Type of Description of After Mitigation Phase Project Activity Rating Before Action measure Impact (Residual Impact (C, O, D)1 Mitigation (MI, CO)2 Rating)

 IEFCL will undertake to educate construction workers and locals on Loss of biodiversity Low the sensitive nature of the MI Very Low biodiversity of the area and the need for conservation

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Significance Rating Project Significance Type of Description of After Mitigation Phase Project Activity Rating Before Action measure Impact (Residual Impact (C, O, D)1 Mitigation (MI, CO)2 Rating)  IEFCL will train its personnel by an Environmental Capacity Building Program for minimizing the environmental impact and risks within the facility and also to awaken the consciousness of environmental protection within them. Encourage the ongoing environmental essay competition during World Environment Day program All  In accordance to the Monitoring construction, Program IEFCL will evaluate possible C+O+D operation and Loss of biodiversity Low effects of the initiative on vegetation MI Very Low decommissionin and wildlife in the area interested by g phases the project. On this basis, if necessary, dedicated actions aimed at minimizing any potential risk in loss of biodiversity will be implemented.  In accordance to the Monitoring Program IEFCL will yearly monitor Hydrobiology parameters in the receiving water body interested by the project. On monitoring basis, if necessary, dedicated actions aimed at minimizing any potential risk in loss of biodiversity will be implemented.

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Significance Rating Project Significance Type of Description of After Mitigation Phase Project Activity Rating Before Action measure Impact (Residual Impact (C, O, D)1 Mitigation (MI, CO)2 Rating)

 Ensure maintenance of roads of any damaged parts caused by CO project activities

Potential increase Medium  IEFCL will adopt a dedicated traffic Low of traffic accidents management plan for the Mobilization, mobilization of vehicles during the Transportation construction, operation and MI of personnel, decommissioning phases to C+O+D materials and minimize the risk of traffic equipment accidents from/to site by road  Transportation activities during night hours will be minimized up to extent possible Increase in noise Medium MI Low levels  IEFCL will verify that all vehicles and equipment conform to World Bank limits for noise

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Significance Rating Project Significance Type of Description of After Mitigation Phase Project Activity Rating Before Action measure Impact (Residual Impact (C, O, D)1 Mitigation (MI, CO)2 Rating)  In accordance to the Monitoring Program. On monitoring basis, if necessary, dedicated actions aimed at reducing any potential effect associable to increased traffic related noise will be Increase in noise Medium implemented MI Low levels  IEFCL will implement a Traffic Management Plan to minimize Mobilization, potential effects on noise levels Transportation associable to the additional of personnel, vehicular movements generated C+O+D materials and by the initiative equipment from/to site by  IEFCL will permit that only vehicles road with pre-mobilization certificates to operate in Project area as to reduce emissions from vehicle Increase in air exhaust pollution (dust, Medium  IEFCL will implement a Traffic MI Low exhaust fumes) Management Plan to minimize potential effects on air quality associable to the additional vehicular movements generated by the initiative

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Significance Rating Project Significance Type of Description of After Mitigation Phase Project Activity Rating Before Action measure Impact (Residual Impact (C, O, D)1 Mitigation (MI, CO)2 Rating)

 IEFCL shall organize training on safe practices for personnel involved in handling, storage and disposal of materials and wastes

 All Use of quality and approved construction, Contamination of storage facility during C+O+D operation and groundwater/surfa Medium construction and operation M1 Low decommissionin ces water as  Adoption of reuse of the waste g phases water in process operation;

 Storage containers should be certified prior to use and periodically checked for leaks during project implementation;

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Significance Rating Project Significance Type of Description of After Mitigation Phase Project Activity Rating Before Action measure Impact (Residual Impact (C, O, D)1 Mitigation (MI, CO)2 Rating)

 IEFCL will ensure that both contractor and IEFCL personnel develops a high level of security consciousness both within and outside the work area

 If required, additional security arrangements will be made to enable the existing federal security forces to cope with such situation All construction C+D and Stress on existing Medium  IEFCL will ensure that a liaison to MI Low decommissioning security structures foster partnership with the phases community so as to guarantee security for the project is established and sustained

 In order to beef up security for the project, IEFCL will contact government authorities to improve the strength of the police force and shall consider providing assistance with equipment to ensure improved security

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Significance Rating Project Significance Type of Description of After Mitigation Phase Project Activity Rating Before Action measure Impact (Residual Impact (C, O, D)1 Mitigation (MI, CO)2 Rating)

 IEFCL will ensure there are Threat to health of workers (snake, adequately trained and sufficient bites, insect stings, numbers of first aiders at each site C Site Preparation injuries, etc.) as Medium MI Low  IEFCL will ensure that anti- potential increase venom/anti-histamine is provided of workplace on site to mitigate snake bites and accidents/diseases insect stings

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Significance Rating Project Significance Type of Description of After Mitigation Phase Project Activity Rating Before Action measure Impact (Residual Impact (C, O, D)1 Mitigation (MI, CO)2 Rating)

 IEFCL will train its personnel by an Environmental Capacity Building Program for minimizing the environmental impact and risks. In accordance to the Monitoring Program IEFCL will periodically verify stack emissions and air quality levels. On the basis of Routine Degradation of monitored data, dedicated actions Operation and ambient air quality for the safeguard of ambient air O Maintenance of Low MI Very Low for emissions of air quality will be implemented if the Fertilizer pollutants necessary plants  IEFCL will implement a Leak Detection and Repair (LDAR) Program that controls fugitive emissions by regularly monitoring. On the basis of monitoring activities, dedicated actions for the safeguard of ambient air quality will be implemented if necessary

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Significance Rating Project Significance Type of Description of After Mitigation Phase Project Activity Rating Before Action measure Impact (Residual Impact (C, O, D)1 Mitigation (MI, CO)2 Rating)

 IEFCL will hold yearly environmental awareness /education programs for the stakeholders to educate more about environmental management systems and practices.

 IEFCL will implement operational MI strategy and actions to reduce Routine leakages and fugitive emissions Operation and Odour annoyance (LDAR Program) O Maintenance of concerns by host High Low the Fertilizer communities  IEFCL will train its personnel by an plants Environmental Capacity Building Program for minimizing the environmental impact and risks

 IEFCL will adopt operational/ technical measures to avoid CO possible emissions within the facility

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Significance Rating Project Significance Type of Description of After Mitigation Phase Project Activity Rating Before Action measure Impact (Residual Impact (C, O, D)1 Mitigation (MI, CO)2 Rating)

Noise pollution;  All vehicles will be made to Gaseous emissions observe the speed limits and that long/large vehicles have warning contaminate/pollu lights to alert other roads; all the te air, land, plants vehicles will be maintained at at roadsides, optimal conditions & ensured that C+O+D Vehicular water; Traffic Medium all the drivers are certified MI Low Traffic incidences and accidents; some fatal Disturbance of wildlife due to large traffic volume

 Segregate by type and store in Routine water-proof metal Operation and Spent catalysts skips/containers for transportation O Medium MI Low Maintenance of and sludge to approved contractor for low the Fertilizer thermal desorption plants

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Significance Rating Project Significance Type of Description of After Mitigation Phase Project Activity Rating Before Action measure Impact (Residual Impact (C, O, D)1 Mitigation (MI, CO)2 Rating) Base camp site for workers:  Workers awareness on HIV/AIDS All construction Influx of migrant and STDs shall be aroused through and O+D workers, Medium posters and oral enlightenment by MI Low decommissioning Contamination nurse-in-charge at the Community phases and spread of Health Centre. Implement HIV/AIDS and STDs

Emission of Oxides  The Process heaters and boilers of Sulphur and will be designed to achieve During O Nitrogen, and Medium emissions to atmosphere as per MI Low Operation particulates FMEnv Guideline.

Excessive noise  Installation of noise reducing All construction and vibrations devices to exhausts & ensuring the C+O+D and from generators, Medium use of earmuffs/plugs by MI Low decommissioning pumps and personnel. phases compressors

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CHAPTER SEVEN ENVIRONMENTAL AND SOCIAL MANAGEMENT PLAN

7.0 MANAGEMENT PLAN The Management Plan identifies strategies and approaches for managing the proposed project and associated impacts related to:  Environmental and Social;  Occupational Health and Safety concerns.

The management plans defines the guidelines, strategies and procedures for managing the significant, possible, potential and associated environmental and social impacts of the proposed project. The identified key environmental and socio-economic aspects and mitigation measures associated with the project are the basis for the management plan. The plan has been defined in accordance with the analyses carried out in the previous chapters of this Environmental and Social Impact Assessment report (ESIA).

This plan is aimed at:  Providing an initial analysis for the subsequent adoption of an Environmental and Social Management System (ESMS) in accordance with the IFC Performance Standard 1.  This plan also aims to provide guidelines for the follow up programs to be carried out by the proponent to assess the effectiveness of procedures laid out subsequent to implementation of ESMS.  Identifying priorities of the actions needed to implement mitigation/compensation measures necessary to manage the impact and risks identified in the Assessment (see the Action Plan reported in appendix 7.3).

IEFCL has developed and implemented a comprehensive regime for management of the Safety, Health, Environment and Social issues. The concept of sustainable development, which covers economic development, environmental protection and social responsibility, is clearly illustrated in the HSE policy.

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The ESMS adopted at IEFCL is based on the best practices adopted in same kind of industries globally. The systems and procedures practised at IEFCL are in line with globally accepted international standards, like ISO 14001, OHSAS 18001 etc. The IEFCL- Train2 project is an expansion of IEFCL-Train1, the same systems and procedures will be extended to new plants.

The following chapters outline the details of the organization having the responsibility to implement ESMS & undertake the monitoring of the follow up program are described below:

IEFCL’s Management Team The management team is headed by a Project Director under whom the following teams are organized: 1. Project Team responsible for the design, engineering, construction & commissioning activities 2. Operations team who will carry out the day to day operations of the Ammonia, Urea & Utilities and Off-sites facilities 3. EHS Team responsible to carry out the environment, occupational health & safety related activities 4. Community relations & Industrial relations department to carry out the social functions

Each team as mentioned above are adequately staffed with equipped with enough resources. Indorama Eleme Fertilizers and Chemicals shall enjoy the synergy of its existing departments in EHS & Community relations function since the IEFCL-Train 2 project is being co-located at the existing Indorama manufacturing complex.

The current strength to manage the above functions include a total of approximately 89 well experienced professionals as described below:

1. Current project team consists of 21 personnel. At peak, the project organization shall grow to about 45 personnel. The project team consist of qualified and well

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experienced professionals in civil, mechanical, electrical & instrument engineering disciplines. 2. The current operations team consist of more than 200 personnel engaged in the operations of IEFCL-Train 1. After about two years, the operations team of IEFCL- Train 2 shall grow by an additional 200 personnel. The operations mainly consist of qualified and well experienced professionals in chemical engineering discipline. 3. The EHS team consists of about 68 personnel considering the synergies available at site. The EHS team consist of environmental engineers, doctors/ nurses and medical professionals, process and construction safety professionals. 4. The community & industrial relations team consist of more than 12 personnel considering the synergies available at site. The community & industrial team mainly consist of social sciences and management professionals.

Through the above adequately staffed teams IEFCL intend to implement ESMS procedures according to the environmental, social, occupational health and safety policies of the company.

On account of the induction of EHS professionals in the project team, Environmental, process safety and industrial safety aspects will be considered upfront during the design, engineering & procurement of plant & machinery.

Functions of Project & EHS Team Besides managing the project and ensuring that the manufacturing facilities are designed and constructed in a safe manner, the Project & EHS team shall also be responsible for monitoring the compliance between the project activities and the ESMS procedures. For the above mentioned scope the unit will:  Compile quarterly reports and send the same to the Project office,  Verify compliance monitoring carried out by construction contractors as well as consultants.  Daily routine check on the site.  Take on the spot decisions to rectify minor problems on site

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 Oversee supervising consultants  Ensure good coordination among various contractors  Ensure healthy relations between the company, community and government regulatory agencies  Manage the training and awareness programs

In compliance with IFC Performance Standard 2, the pursuit of economic growth and income generation through employment creation shall be ensured. Towards the same, the community relations team shall oversee that the protection of the fundamental rights of workers are respected by various contractors through compliance to labour laws.

Project Management Consultant As part of the company’s efforts to ensure highest level of quality control, about 30 well experienced constructions professionals in each discipline including environmental engineering and construction safety shall be mobilized at site. This team shall work alongside the project & EHS team as their extended arm to realize the project objectives.

Construction Supervision It is mandatory for all IEFCL contractors to deploy environmental and safety engineers/officers as part of their scope of services to ensure that each activity is monitored and controlled at the very first level itself. These engineers/officers will monitor site activities, verify the implementation of ESMS management plan as per IEFCL specifications, arrange for the monitoring of social, occupational health, safety and environmental conditions as per the monitoring Plan and also prepare the reports to be submitted to the project team.

The Environmental and Safety Engineer(s)/officer(s) duties shall include:  The proper construction and maintenance of the facilities at the project sites;  The measurement and verification for environmental and safety enhancement, ensuring that proper safeguards are being maintained at all times.

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Environment Consultants IEFCL will be deploying a reputed third party environmental consulting agency to audit all aspects of environment management including the monitoring of any form of pollution of the environment. This agency shall be used to provide independent audit reports to the top management as a quality assurance check. IEFCL considers the independent audit by Environmental Consultant as critical element in the EHS management plan.

7.1 ENVIRONMENTAL MANAGEMENT PLAN

Introduction The Environmental Management Plan (EMP) identifies policies and approaches for managing the potential environmental impacts associated with the project and also to ensure the compliance of the applicable international and national environmental regulatory standards and guidelines.

The overall objective of EMP is to ensure the progressive reduction of the impact of any project activity on the environment. This objective shall be achieved through a combination of:  Appointing adequately trained staff responsible for implementation of EMP  Ensuring periodic training of construction personnel  Environmental Capacity Building Program;  Environmental Monitoring Program;  Audit Program;  Energy Conservation Program;  Leak Detection and Repair Program;  Risk Management Plan for Contaminated resources;  Hazardous Materials Management Plan;  Waste Management Program

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 Traffic Management Plan;  Decommissioning and Closure Plan

7.1.1 Environmental Capacity Building Program The training and awareness are the key aspects considered in capacity building program. The training system implemented through long term association of environmental consultants to optimize the Project competencies are described below:

Training Needs The Managers (Project team members) & the personnel of the Construction Contractor shall be trained on environmental issues. Training needs of target groups shall be prepared in advance to ensure the success of the implementation.

Target Groups for Training All members of the project team, staff of the construction contractors directly responsible for delivery of collaborating services, shall be trained and retrained as primary target groups. They are divided into the following target groups:  For Project Team – Specific training in EMP implementation, environmental design and environmental conflict resolution.  Construction Supervisors - Training in environmentally acceptable processes, methods and equipment of construction.  Senior staff - Understanding of the environmental policies and awareness programs.

Training Program The program will consist of a number of training modules specific to target groups. The training would cover the basic principles and postulates of environmental assessment, mitigation plans and programs (Operational Guidelines and National Policy Perspectives), implementation techniques, monitoring and management.

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Looking into the potential requirements of each of the target groups, several training modules are suggested below:  Module I: Environmental Overview

 Module II: Environmental Regulations and Acts

 Module III: Pollution Prevention

 Module IV: Environmental Impact Assessment

 Module V: Environmental Management System

 Module VI: Mobilization and Environmental Issues

 Module VII: Environmental Issues in the Project

 Module VIII: The Environmental Management Plan for construction Projects

 Module IX: Environmentally Sound Construction Management

 Module X: Long Term Environmental Management Issues

The training modules are combined into different training components. There are overlaps in the composition of the target groups and the constitution of the training components. However, each training module would be developed keeping in view the composition and responsibilities of the target group members. Other components may be imparted throughout the implementation period and held in the initial months of project implementation, preferably on site.

The following tools are expected for the implementation of environmental training programme:  Informal Training Sessions;  Audio-Visual Communications;  Case Studies;  Lecture Sessions;  Workshops;  Group Discussions;

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 Short-Term Training Courses;  Seminars;  Additional Training Modules;  Full-term Training Courses.

7.1.2 Monitoring Program Environmental monitoring plan is designed to ensure that the applicable international and national environmental regulatory standards and guidelines shall be complied with. IEFCL shall comply with National regulatory controls by establishing an ecological monitoring program that shall cover the entire project development phase till the performance test of the facilities performance (i.e. pre-Construction through operation phases including decommissioning phase). This program will help to generate information on the impacts, which, in comparison with predicted impacts, will forewarn any adverse variation in the ecological components. The environmental monitoring approach shall be made to form part of the existing monitoring plan. The environmental components to be monitored shall include but not limited to:  Land Use;  Climate;  Vegetation/Wildlife;  Hydrobiology;  Noise;  Stack Emissions;  Air Quality/Odor (ground level pollutants concentration);  Surface Water;  Sediment  Groundwater;  Treated Waste Water;

For simplicity of discussion, social components (Socio-economic Condition and Community Health) as foreseen in the Social Management Plan (see par. 7.3) have also been included. The broad objectives are:

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 To evaluate the performance of mitigation/compensation measures proposed in the EMP;  To evaluate the adequacy of Environmental Impact Assessment;  To evaluate the adequacy of Waste Management Plan in connection with environmental aspects;  To suggest improvements in ESMS, if required;  To enhance environmental quality;  To satisfy the legal and community obligations.

7.1.2.1 Performance Indicators The following Table 7.1 shows the physical, biological and social components identified as of particular significance for the environment. For each component, specific key performance indicator to be monitored at critical locations have been identified.

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Table 7.1: Monitoring Plan for the IEFCL-Train2

Environmental Remarks/ Responsible Indicator Parameters Frequency1 Location Responsibility Components Regulatory Agency

Treated Waste  PH , Ammonia  Daily  Plant level from  IEFCL QAQC  Quarterly report to water-2 fertilizer plant NESREA,FMENV& RSMENV

 PH , Ammonia  Daily  Plant level entire  IEFCL QAQC  Quarterly report to Treated Waste fertilizer facility NESREA,FMENV& water -3 RSMENV

 pH, BOD, COD, Heavy metals, TSS, TDS, Oil and grease,  Third Party  Quarterly report to Treated Waste NH , Chloride, etc.  Complex discharge 3  Monthly (Environmental NESREA,FMENV& water -1 as it relates to point Consultants) RSMENV Fertilizer production

specified in FMENV 1991

1The duration of all environmental components monitoring will continue through the life cycle of the project.

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Environmental Remarks/ Responsible Indicator Parameters Frequency1 Location Responsibility Components Regulatory Agency

 NH3  IEFCL Environment  SPM/PM10/PM2.5 Air Quality  Plant site and Department  NOx  Quarterly report to (ground level selected community  Monthly NESREA,FMENV & pollutants  SOx based stations (total  Third Party RSMENV concentration)  CO 4 no.) (Environmental  Noise Consultants)

 Dissolved Oxygen  Nutrient Content  Ammonia  Nitrate   PH  Surface water along IEFCL Environment Okulu stream Department  Biological Oxygen  Quarterly report to Surface Water upstream and  Monthly NESREA,FMENV & Quality Demand (BOD) downstream,  Third Party RSMENV  Chemical Oxygen Indorama complex (Environmental Demand (COD) discharge outfall Consultants)  Heavy metals concentration  Oil and grease

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Environmental Remarks/ Responsible Indicator Parameters Frequency1 Location Responsibility Components Regulatory Agency

Point sources:  SOx;  Boiler stack: NOx,  NOx; SOx;  Third Party  Quarterly report to Stack emission  PM;  Quarterly  Reformer stack: (Environmental NESREA,FMENV &  NH3; NOx, SOx Consultants) RSMENV  Granulator stacks: PM, NH3

 Third Party  Quarterly report to  Land Use Waste production  Yearly  Project site (Environmental NESREA,FMENV & Consultants) RSMENV

 Macro/micro  Third Party  Quarterly report to Climate climatic data  Yearly  Within project site (Environmental NESREA,FMENV & Consultants) RSMENV

 Record of  Third Party  Quarterly report to vegetation /  Around the project Vegetation/wildlife  Yearly (Environmental NESREA,FMENV & site wildlife status Consultants) RSMENV

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Environmental Remarks/ Responsible Indicator Parameters Frequency1 Location Responsibility Components Regulatory Agency

 Ammonia  Nitrate  pH  Biological Oxygen  IEFCL Environment  At least two (2) Demand (BOD) Department bore holes  Yearly report to Ground Water  Heavy metals  Yearly strategically located FMENV, RSMENV & Quality  Third Party concentration will be used as NESREA (Environmental  Chemical Oxygen monitoring wells. Consultants) Demand (COD)  Oil and Grease  Consumption

 pH  IEFCL Environment  Along Okulu stream Department  Heavy metals  Yearly report to Upstream, Sediment Quality  Yearly FMENV, RSMENV, concentration downstream and  Third Party NESREA  TPH outfall (Environmental Consultants)  Diversity and  IEFCL Environment  Surface water along abundance of Department Okulu stream  Yearly report to

Hydrobiology organisms  Yearly upstream, FMENV, RSMENV,  Third Party (benthos, fish, downstream and NESREA (Environmental plankton) outfall Consultants)

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Environmental Remarks/ Responsible Indicator Parameters Frequency1 Location Responsibility Components Regulatory Agency

 Population  IEFCL Community  Health status Relation  Infrastructural and Department and  IEFCL will regularly Community Public Affairs Unit hold stakeholders Socio-economics Development and and Community  Yearly  Host Communities Forum with the Assisted Projects Health  Third Party representatives of  Number of (Environmental & the communities Employed youths Socio-economic from the Consultants) communities.

DECOMMISSIONING  Decommissioning &Closure plan will be All affected  All agreed  IEFCL executed after Environmental parameters -- -- Environmental successful discussion Components Department with all affected Regulatory Agency

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7.1.2.2 Environmental Monitoring Reporting System Monitoring involves periodic checking to ascertain whether activities are going on according to the plans and the in accordance with Key Performance Indicators laid out by regulatory agencies. There will be the following important aspects of reporting which are under the responsibility of the Project EHS Lead and reputed Environmental Consultants (ECO):  Reporting on progress;  Environmental compliance monitoring. The reporting system will operate linearly with the Contractor (which is at the lowest rung of the implementation system) reporting to the Supervising Consultant, which reports to the Project EHS Lead that finally reports to the Project Director. The environmental compliance monitoring performed by ECO and by in-house EHS team and the progress reports on environmental components will be clubbed together and submitted to the FMENV quarterly during the implementation period. Photographic records shall also be established to provide useful environmental monitoring tools. A full record shall be kept as part of normal contract monitoring.

7.1.3 Audit Program Environmental audit will be conducted on the project as called for by the relevant Regulators. This audit process shall be used to check the prediction in the ESIA and also to assess the environmental performance during the operational phase of the project. This will ensure that environmental protection and management procedures are reinforced.

The audit program shall:  Examine compliance with regulatory requirements;  Identify current and potential environment problems especially during the Operational phase of the project;  Check the predictions in ESIA and assure implementations and application of recommended practices and procedures.

Indorama Eleme Fertilizer & Chemicals Limited shall produce an Environmental Audit Report (EAR), which shall be submitted to FMENV and State Environmental Authorities.

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7.1.4 Traffic Management Plan Measures on transportation/traffic will be adopted to minimize the impact due to the mobilization of trucks and other vehicles for the construction and operation phases. The following mitigation measures shall be taken into account for transportation management of heavy equipments, construction materials, products and personnel:  Large and slow moving vehicles shall be scheduled during off peak periods  Raise community awareness in case of transportation of equipment having over dimensional crate (ODC)  Vehicle speed limits shall be strictly enforced;  Contractors/Company Drivers will receive safety and environmental awareness training, and shall be subjected to assessments and monitoring;  Construction vehicles shall be restricted to approved access roads;  Vehicles will be maintained to minimize emissions and fuel consumption;  Warning signs will be placed at road crossings and other appropriate locations as required;  Temporary traffic control shall be established where necessary at road crossings and junctions.  Traffic wardens shall be deputed for monitoring and controlling of vehicle speed.

The IEPL and IEFCL facilities attract vehicles of different type on daily basis. On an average, about 400 vehicles come & leave the facility each day. The fertilizer expansion project IEFCL- Train2 will increase the present traffic flows. In view of this a traffic survey was conducted traffic management plan was developed. This plan is attached as Appendix 7.1 and shall be implemented with the above mentioned measures.

7.1.5 Energy Conservation Program Energy conservation shall be the basis for project engineering. Energy conservation as part of design criteria shall be considered to effectively operate the plant on regular basis. This has tangible benefits in the long run. An energy conservation program shall be adopted for the facilities (process and auxiliary) that consume energy in process, heating and cooling during operational phase

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Common techniques/measures/procedures may be applied in accordance with the chapter 1.2 of the IFC general EHS Guidelines (April 30, 2007). 7.1.6 Leak Detection and Repair program Referring to the possible fugitive emission due to the operation of the Fertilizer plants, IEFCL shall implement a leak detection and repair (LDAR) program that controls fugitive emission by regular monitoring to detect leaks and implement repairs within a predefined time according to the IFC general EHS Guidelines concerning the fugitive sources.

7.1.7 Risk Management Plan for Contaminated Land IEFCL shall define the contents/indications to be developed/followed in case of land contamination due to anthropogenic releases of hazardous materials, wastes or oil, including naturally occurring substances. IEFCL already has a hazardous waste management plan that tracks waste from “cradle to grave”. This analysis shall be considered for the identification of dedicated ESMS procedures according to IFC EHS guidelines (1.8 “Contaminated Lands”).

7.1.8 Hazardous Materials Management plan The Hazardous Materials Management Plan shall be consistent with Occupational Health and Safety Management plan, including:  Written process safety parameters (i.e., hazards of the chemical substances, safety equipment specifications, safe operation ranges for temperature, pressure, and other applicable parameters, evaluation of the consequences of deviations, etc.);  Written operating procedures;  Compliance audit procedures. Hazardous materials shall be stored within designated storage areas and using appropriate procedures (e.g. containment and bounding, impermeable surfaces, secure drainage, limited access, labeling). Hazardous materials management plan shall conform to IFC EHS guidelines (1.5 Hazardous Materials Management).

A record shall be kept of all hazardous materials on-site. The Material Safety Data Sheets (MSDS) shall be maintained by EHS and Fire department and also safety precautions shall be displayed at storage site. The hazardous material shall be stored as per compatibility and potentially reactive materials will be segregated and stored separately.

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Personnel shall be trained in safe use & handling of hazardous materials. Spill response equipment (absorbents, etc.) will be available and emergency response training provided.

7.1.9 Decommissioning and Closure Plan The activities shall involve demolition and site clean-up, disposal of wastes, Demobilization and final site review, after plan has been reviewed and approved by FMENV & State Environmental Authorities. Any possible measure shall be taken in order to avoid negative impacts during decommissioning phase to take place. IEFCL commits itself to restore the environmental conditions existing before the realization of the Fertilizer project.

7.1.10 Waste Management Program Waste management programs for IEFCL-Train2 project shall be implemented to address all activities that have been identified to have potential significant impacts on the environment with respect to waste generation and disposal during construction, operation and decommissioning. Consequently, waste type to be generated during the construction, operation and decommissioning of this project has been classified into the following: Domestic waste These are waste generated from the daily operations of the offices and canteens within the facility. Composition of the waste will include the following:  Paper  Glass  Plastics and Nylons  Metal (off spec materials)  Food residues  Sanitary wastes Hazardous waste These are waste generated from the daily operations of the fuel dispensing area, lube oil service bay, and above ground storage containments within the facility. These categories of waste include solid/liquid substances or mixtures of substances capable of causing fire. Composition of waste will include the:  Used/spent oil

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 Wastes/residues containing oil  Oily sludge/emulsions  Spent chemicals Waste Handling and Disposal Domestic Waste Collection and Storage The facility will be equipped with waste bins for the collection and segregation of the following categories of domestic waste:  Biodegradables: food remains  Incinerables: plastics, waste papers, etc.  Recyclables: metal articles, glass etc. Aspects to be considered in the selection of the waste bin types shall include:  Hygiene (exclusion of insects, rodents and odor); which may be achievable through provision of adequate cover, and spraying of insecticides or microbial inoculums.  Adequate capacity to forestall garbage spill;  Weather resistance (impermeability);  Convenience of use (color coding for ease of use), and  Aesthetic acceptability

Domestic Waste Disposal The domestic waste generated from the facility shall be disposed of in the most pragmatic and environmentally acceptable manner. Domestic waste from the facility shall be finally disposed- off at approved dump site by approved contractors. The options of recycling, reusing, or composting shall be considered at the dumpsite.

Hazardous Waste Collection and Disposal The collected hazardous waste shall be transported by a licensed waste disposal contractor, using an appropriate waste disposal vehicle. The final disposal of the waste shall be carried out at an approved waste disposal facility, after due treatment, to an environmentally acceptable level.

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7.2 OCCUPATIONAL HEALTH AND SAFETY MANAGEMENT PLAN IEFCL will adopt an Occupational Health and Safety management plan according to IFC EHS guidelines 2.0 Occupational health and Safety in order to protect their worker from occupational hazards. A Communication and Training Programme to ensure that all the employees involved in the project receive training about Occupational Health and Safety (OHS) aspects, according to IFC, EHS guidelines 2.0 Occupational health and Safety will be put in place.

The existing IEFCL Train1 Contingency/Emergency plan to ensure that all employees are capable of acting in an emergency so as to protect human life and property shall be periodically reviewed to accommodate the activities of IEFCL-Trains2. Safety and emergency procedures shall be defined also for chemical hazards, directly referable to the operation of the new fertilizer plants (e.g. spills or leakage of hazardous substances).International codes to be considered for incorporation into the design, construction and maintenance of the proposed fertilizer plants and shall be in accordance with International Codes Council (ICC, 2006). The OHS shall include the Hazardous Materials Risk Management plan.

7.2.1 Hazardous Materials Risk Management Plan In addition to the application of the above-referenced guidance on prevention and control of releases of hazardous materials, IEFCL shall implement a Hazardous Materials Risk Management Plan containing the following elements for handling, storage and use of hazardous materials:  Management actions to be addressed;  Use of appropriate PPEs  MSDS of each chemical  Proper house-keeping  Preventive Measures to be taken;

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 Emergency Preparedness and Response to be developed;  Community involvement and Awareness in relation to potential hazards. The objective is the prevention and control of the potential industrial risk.

7.3 SOCIAL MANAGEMENT PLAN (SMP) IEFCL will adopt a Social Management plan according to the Equator principles and the IFC EHS guidelines 3.0 Community Health and Safety. The security will be assured by the existent dedicated security personnel. Their action will be monitored by the Proponent to assure that the possible use of force will be adopted according to the law.

According to the Equator Principle n. 5, the Proponent will assure the consultation and participation of affected parties in the implementation of the Project.

IEFCL has developed a Stakeholder Engagement Plan and will be implemented. The implementation of Stakeholder Engagement Plan will encourage the participation of relevant Stakeholders in various project phase with ensuring the equally socio-economic development of communities. Where applicable, the Stakeholder Engagement Plan include differentiated measures to allow the effective participation of those identified as disadvantaged or vulnerable.

The Proponent shall provide Affected Communities with access to relevant information on: (i) the purpose, nature and scale of the project; (ii) the duration of proposed project activities; (iii) any risks to and potential impacts on such communities and relevant mitigation measures; (iv) the envisaged stakeholder engagement process and (v) the grievance mechanism to express their concern with respect to the project.

Social conditions of the host communities shall be monitored as previously indicated in Table 7.1 (Monitoring Plan).

SMP shall be fully implemented and establishment of community liaison team enforced to facilitate relationships with communities during the construction, operation and decommissioning phases. The Stakeholder Management Plan is included as appendix 7.2.

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The Labour and Working conditions shall be in compliance with IFC Performance Standard 2. Development of a code of conduct for construction workers, and disciplinary procedures is expected to guide the activities of construction workers, in addition to security control in order not to comprise the well-established security system existing in Indorama complex. .

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