CHAPTER ONE

1.0 INTRODUCTION

1.1 Project title: Construction of an Independent Power Plant (IPP)

1.2 Applicant: Total E & P Nig. Ltd.

1.3 Location: OML58, close to OGP, about 100km West of Port Harcourt

1.4 Project Description

The applicant proposes to undertake the construction of an Independent Power Project (IPP) in her
OML 58 field area. The proposed project shall consist of a 400MW capacity combined Cycle Power
Plant that will be connected to the National transmission grid. The gas supply is designed to provide
a maximum capacity of about 65mmscfd, and it is planned to commence operation before the end
of 2010.

1.5 Project duration: 18 months (construction)

1.6 Objectives
The purpose of this plan is to manage the potential project delivery/HSEQ risks associated with the
project in compliance with relevant legislation by:
 Identifying relevant regulations that are applicable to the proposed project;
 Describing the project/HSEQ plans for the OML 58 IPP project for all phases of the proposed
project (design, construction, operations & maintenance, and decommissioning) where
there are potential project delivery/HSEQ risks;
 Evaluating the risks, and recommending reasonable and cost-effective control measures to
be followed during these phases; and
 Provide guidance on the management programmes including compliance monitoring,
auditing, and contingency/emergency planning.

1.7 Work Approach

Data for the assessment were obtained through the use of photographs, maps, questionnaires,
interviews, existing literature, field sampling/collection of specimens, surveys and laboratory
analyses of samples. These data enabled the determination of the state of the existing environment,
the evaluation of potential risks of the project activities, and the development of mitigation and
ameliorative measures.

This approach involved collation of various reference materials namely:

 FME Procedural and Sectoral Guideline or Oil and Gas industry projects.
 DPR Environmental Guidelines and Standards for the Petroleum Industry in Nigeria (EGASPIN
2002).
 Project environment (ecological, biophysical and socio-economic) baseline description.
 Project design reports, maps and drawings.
 Environmental Assessment Reports of ElIf Petroleum Nigeria Limited for the area:
1. EBS for Obite Gas Plant (1998).
2. EBS and EIA for OML 58 Complementary Drilling Project (2002).
3. EBS data acquisition and EER of OML 58 2003.

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 4. EBS data acquisition and EER of OB 90 pit situation in OML 58.
5. EBS and EIA for OML 58 Infill Drilling Programme EBS data acquisition for OML 58
Material Recovery 2004.

1.7 LEGAL FRAMEWORK

Since the Rio de Janeiro declaration emphasis has shifted from mere development to sustainable
development. All over the world, the awareness has been on resource conservation for
sustainability. This has necessitated all the various environmental regulatory bodies in Nigeria to
make regulations that would enhance environmental protection. The Federal Ministry of
Environment, the Department of Petroleum Resources, the State Ministries of Environment and the
Local Government By-laws have regulations hinging on environmental protection, restoration and
conservation. Some of the legislations required for environmental impact assessment are:

1.7.1 The Environmental Guidelines and Standards for the Petroleum Industry in Nigeria. EGASPIN
(Revised Edition 2002)

The Department of Petroleum Resources has the mandate of supervising the activities of oil and gas
related activities in Nigeria. The agency requires all license holders of exploration, prospecting,
exploitation, refining, transportation, marketing of petroleum resources to adopt practicable
precautions to prevent the pollution or cause as little damage as possible to the surface areas of
operation.

The Department of Petroleum Resources (EGASPIN 2002) clearly spell out in Part VIII, Article 2.0 as
that "the Environmental Evaluation Report evaluates the already polluted or Impacted environment
to enable the government know how good or bad (i.e., the state of the environment) the recipient
environment is so as to decide and design strategies for protection and restoration.’

1.7.2 Federal Ministry of Environment (FMENV) Guidelines on National Environmental Protection

The Federal Ministry of Environment (FMENV) has put in place statutory documents to aid in the
control and abatement of e.g., industrial wastes including indiscriminate pollution of the
environment. Some of the statutory documents are:
 The Harmful Wastes (Criminal Provisions) Decree 36 of 1988.
 The 1989 National Policy on the Environment.
 EIA Act No 86 of 1992, The Federal Ministry of Environment (FMEN) developed a National
EIA procedure in response to the promulgation of the EIA Decree No. B6 of 1992 The
procedure in dictates the steps to be followed from project conception to commissioning in
order to ensure that the project is implemented with maximum consideration for the
environment.
 The procedure for EIA involves the project proposal stage where the project proponent
notifies FMENV of the proposed project in writing. This stage is followed by actual
implementation of the EIA study, preparation of Draft Final and Final EIA Reports, review
process and approval/certification. The Federal Ministry of Environment (formerly FEPA) EIA
procedure is represented in Figure 1.1. Apart from the general EIA Guidelines, the Ministry
has also prepared sectoral guidelines for EIA in different industrial sectors including the oil
and gas sector.
 S 1.8 - National Environmental Protection (Effluent Limitations) Regulations of 1991.

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  S 1.9 - National Environmental Protection (pollution Abatement in industries and Facilities
Generating Wastes).
 S 1.15- National Environmental Pollution Management of Solid and Hazardous Wastes
Regulations of 1991.
 1992 National Guideline and Standards for Wastes Management in the Oil and Gas Industry.

These statutory documents spell out clearly:

i. The restrictions imposed on the release of hazardous wastes and toxic substances into the
environment, and
ii. The responsibilities of all industries whose operations are likely to pollute the environment.
Such responsibilities include provision of anti-pollution equipment, adequate treatment of
effluent before being discharged into the environment, etc. (S 1.8 & S 1.9), For example.
paragraph 15 (2) of S 1.9 states that no oil in any form shall be discharged into public drain,
rivers, lakes, seas, atmosphere or underground injection without the permit issued by
FMENV or any organisation designated by the agency. Paragraph 17 of the same section also
states that an industry or a facility which is likely to release gaseous, particulate., liquid or
solid untreated discharges shall install into its system, appropriate abatement equipment in
such a manner as may be determined by the agency.

1.7.3 National Policy on the Environment

The overall goal of achieving sustainable development in Nigeria is the main aim of the National
Policy on Environment [1989). Its provisions include:

 Monitoring for all Nigerians a quality of environment adequate for their health and well-
being, conserving and using the environment and natural resources for the benefit of
present and future generations,
 Restoring. maintaining and enhancing the ecosystems and ecological process essential for
the functions of the biosphere to present biodiversity and the principle of optimum
sustainable yield in the use of living natural resources and ecosystems,
 Raising public awareness and promoting understanding of essential linkages between the
environment and development, and to encourage individual and community participation in
the environmental improvement efforts, and
 The co-operation in good faith with other countries, international organisation/agencies to
achieve optimal use of trans-boundary natural resources and effective prevention or
abatement of trans-boundary environmental pollution while stipulating an environmental
problem-solving approach predicated on an integrated, holistic and systemic view

The policy details implementation strategies for the various sectors such as the human population,
land use and conservation, water resources management, forestry/wildlife protected areas, marine
and coastal resources, sanitation and waste management, toxic and hazardous substances mining
and mineral resources, agricultural chemicals, energy production and use, air pollution, noise
pollution, working environment [occupational, health and safety], settlements recreational space,
greenbelts monuments and cultural property. The policy also provides for public partic1pation,

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institutional arrangements, legal basis, obedience to international treaties and obligations &
monitors and evaluation.

The Petroleum Act of 1969

This regulation empowers the Ministry of Petroleum Resources to make regulations for the
conservation of petroleum resources, prevention of pollution of watercourses and atmosphere.

Other legislation made include,

 The Mineral Oils (Safety) Regulation Of 1963,

 The Oil Pipeline Ordinance Of 1956

These regulations were made for the protection of the Nation's environments.

1.7.4 Rivers State Environmental Protection Agency (RSEPA) Edict

The edict establishing the Rivers State Environmental Protection Agency (RSEPA) was signed into law
on the 4th of January 1994 as Edict No. 2 of 1994. The edict clearly spells out the functions of the
agency as far as the protection of the environment for sustainable development is concerned. The

functions of the agency that are related to the present study are summarized below:

1 The Agency would liaise with project developers and conduct Environmental Assessment of
new and existing projects and make recommendations for corrective measures where
necessary (Section 6 (4) (K);
2 The Agency would monitor and control the discharge and disposal of solid, liquid and
gaseous industrial waste products (Section 6(4) e (ii);
3 It should survey and monitor the waler, air, land and soil environment in the state to
determine pollution levels, if any in them, and collect baseline data there from. Also, it
should survey and monitor all portable water distributed in the state for the purpose of
controlling its quality {Section 6 (4) (d; i and ii);
4 The agency shall co-operate with the Federal Ministry of Environment, State Environmental
Protection Bodies, Federal and State Ministries, Local Government Councils, Statutory
bodies and Research agencies on matters and facilities relating to environmental
protection. (Section 51 (3)).

In addition to these functions, the edict empowers the Agency to:

 Establish such environmental criteria, guidelines. specifications or standard for the

protection of the State's air, land and waters as may be necessary to protect the health and
welfare of the people;
 Establish procedure for industrial or agricultural activities in order to minimize damage to
the environment and natural resources from such activities.

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  Ensure that any waste products generated as a result of manufacturing or business
operations are treated or purified to the standard approved by the agency.
 Ensure that no person shall discharge or cause to be discharged raw untreated human,
industrial or other waste products into any public drain, water course, stream, canal, pond,
lake, or into any high way or other land without the approval of the River State Ministry of
Environment.
 Ensure that no person shall discharge any form of oil, grease or spent oil produced in the
course of any manufacturing operation or business into any public drain, watercourse,
stream, canal, pond, highway or other land.
 Ensure that no person shall discharge into the air any unfiltered or impure gaseous waste, or
gases containing substance such as sulphur oxide, oxides of nitrogen, hydrogen sulphide,
carbon monoxide, ammonia, chlorine, smoke and metallic dust and particles.
 Ensure that no industry, which emits obnoxious gas which is injurious to people's health or
which generates a lot of noise, shall be sited within a radius of a least 100m from residential
area.
 Ensure that any Spillage or seismic survey that results in pollution or devastation of the
environment shall be reported by the affected Community on one hand, company, group of
persons, individual on the other hand to the Rivers State Ministry of Environment and Local
Government Liaison Offices within 48 hours.

1.7.4 International Conventions.

The Nigerian government has become an important player in the international support for the
protection of the environment to ensure sustainable development. Such conventions and laws state
clearly the responsibilities, attitude, contributions, etc. of signatory nations towards this particular
cause.

Some other international conventions and Laws related to the present study and to which the
Nigerian Government is a signatory include:

 Basel Convention on the Trans-boundary Movement of, Hazardous Wastes and their
Disposal of 1969.
 Conventions on the Protection of the World Cultural and Natural Heritage of 1972;
 Convention of the Conservation of Migratory Species of Wild Animals of
 1979;
 The Montreal Protocol on substances that deplete the Ozone Layer of 1987;
 The Framework Convention on Climate Change of 1992;
 The Convention on Climate Change of 1997, (the Kyoto protocol);
 The Convention on Biological Diversity. 1992;
 United Nations Framework for Climate Change (UNFCC) Convention (1992).

1.7.5 Environmental Standards applicable

This part summarizes the regulations applicable to the IPP Project. They are in complete coherence
with the National regulations of Nigeria.

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Air quality

Pollutants Unit 1 hour mean Daily mean Annual mean

NOx µg/Nm3 400 150 40
CO mg/Nm3 30 10 N/A
SO2 µg/Nm3 350 125 N/A
PM10 µg/Nm3 N/A 70 20

For information, the National air quality guidelines outlined in the EGASPIN (Guidelines described in
part 1.7.1.) are indicated in the following table:

Pollutants Unit 1 hour mean Daily mean Annual mean

NOx µg/Nm3 400 150 N/A
CO mg/Nm3 30 10 N/A
SO2 µg/Nm3 350 100 – 150 40 – 60
PM10 µg/Nm3 150 – 230 60 – 90 40 – 60 (Black smoke}

Water Effluent

No water will be emitted out of the OML 58 site, as outlined in part 3.4.3.1. All water will be treated,
and then sent to the evaporating lined pit for evaporation. The evaporating pit will be located on the
industrial site.

Noise Levels

The maximum noise levels allowable on the different parts of the site are outlined here after.

Permissible noise level at 1m around GT 85 dB[A]

Permissible noise level at 1m around ST 75 dB[A]
Permissible noise level at 10m around condenser 75 dB[A]
Permissible noise level for other equipment 75 dB[A]
Permissible noise level in working areas 85 dB[A]
Permissible noise level in the control room 50 dB[A]
Permissible noise level at the site fence 60 dB[A]

1.8 JUSTIFICATION AND BENEFITS OF THE STUDY

The benefits of this EIA include the following:

 Obtaining a permit or authorization. Prior to the commencement of the execution of any
development, a regulatory approval or permit must be secured. This is dependent on the
completion of an EIA study.
 Being a planning and management tool that makes for proper accounting and inclusion of
environmental issues and concerns into project designs and implementation,
 Serving as forum/media for all stakeholders to address problems, impacts and mitigating
measures of the proposed project through its consultation processes, and
 Cost saving approach through the achievement of long-term management objectives and
elimination of environmental risks that are associated with project development.

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1.8 Structure of the Report

The report is presented in eight chapters

The first chapter is an introduction and gives the relevant information about the applicant, (Elf
Petroleum Nigeria Limited), the background information of the project and regulatory framework for
the project.

The second chapter gives the project justification and highlights the setting.

Chapter three presents a summarized description of the technical details of the proposed
Independent Power Project.

The fourth chapter presents the ecological baseline status as well as the socio-economic and health
status of the area.

Chapter five presents the perceived potential and associated impacts of the proposed project.

Chapter six discusses the mitigative/ameliorative measures proposed for the perceived potential
impacts of the proposed project.

Chapter seven discusses the Environmental Management Plan that would be adopted for the
project. It also recommends an environmental monitoring programme.

Chapter eight is a presentation of the conclusion of the EIA Study

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 CHAPTER FIVE

5.0 POTENTIAL AND ASSOCATED IMPACT ASSESS MENT

5.1 GENERAL

The whole essence of an EIA is to predict the potential impacts of a proposed project with a view to
proffering mitigative measures for all adverse impacts and enhancing the beneficial impacts. In
pursuance of its policy on environment and in compliance with relevant national and international
laws and conventions and acceptable industry standards, EPNL has embarked on this impact
assessment prior to commencing the proposed Independent Power Project (IPP) in OML 58. EPNL'S
intention is to predict, identify, interpret and communicate the impacts of the various phases of the
project on all facets of the physical and socio-economic environment. This Chapter evaluates the
potential impacts of the various project activities of the proposed IPP on the bi-physical, socio-
economic and health aspects of the catchments area. The steps adopted for the impacts assessment
of the proposed project are presented in Fig. 5.1.

5.2 CONCEPTS AND PRINCIPLES OF IMPACT PREDICTION AND EVALUATION

Impact assessments are required for all major public and private actions that might significantly
affect the quality of the physical and human environment. Impact assessments provide reasoned
predictions of the possible consequences of policy decisions and thus permit wiser choices among
alternatives or options.

For this study the impact prediction and evaluation were based on a sound methodological
framework, which considered the following:

 The overall prediction and evaluation process

 Choice of prediction technique
 Criteria for evaluating significance
 The design of mitigation measures
 Indirect impacts, long range impacts and uncertainty

5.3 Impact Assessment Methodology

Several techniques and methodologies exist for the assessment of potential impacts of the proposed
project. Some of these techniques include the following:

 The overlays techniques (McHarg (1968)

 Leopold matrix, (Leopold et al., 1971)
 Battelle Environmental Evaluation System (Dee et al., 1973)
 Peterson Matrix (Peterson et al., 1974)

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 Identify Associated and Potential Impacts

(Checklist Method)

Predict Impact Magnitude and Importance

(Empirical Worse Case Model and Consensus Opinion)

Evaluate Significance of Importance

(Regulatory Approach)

Proffer Mitigation Measures in-line with the following strategies:

 Avoidance
 Reduction
 Compensation

Figure 5.1: The steps adopted for the Potential Impacts Assessment

For this project a modification of the International Organisation for Standardization (1SO 14001)
Environmental Management System approach was adopted for impact assessment.

In this system, two stages were involved in assessing the impacts. The first stage classified the
impacts as either adverse (negative) or beneficial (positive), shot-term (X) or long-term (L), reversible
(R) or irreversible (I). Adverse impacts are those which impact negatively on the bio-physical, health,
and social environment, while beneficial impacts are those which enhance the quality of the
environment. For this study short term means a period of time less than three months while any
period greater than three months is considered long-term. By reversible/irreversible, we mean
whether the environment can either revert to previous Conditions or remain permanent once the
activity causing the impact is terminated.

The second stage involves evaluation to determine whether or not the impact is significant. The
criteria and weighting scale used in evaluating this significance are as follows:

 Legal/regulatory requirement (L)

 Risk factor (R)
 Frequency occurrence of impact (F)
 Importance of impact on an affected environmental component (l), and
 Public perception/interest (P)

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The quantification scale of 0, 1, 3, and 5 was used. This is a modification of the arbitrary scale
proposed by Vesilind, et al. (1994). The ratings are as described below and adapted from
International Organization for Standardization ISO 14001.

These criteria and ratings are as follows:

 Legal/Regulatory Requirement (L) - is there a legal/regulatory requirement or a permit required?

0 = There is no legal/regulatory requirement
3 = There is legal/regulatory requirement
5 = There is legal/regulatory requirement and permit required
 Risk Factor (R) - What is the risk/hazard rating based on the Risk Assessment Matrix?
1 = Low risk
3 = Intermediate risk
5 = High risk
 Frequency of Impact (F) - What is the frequency rating of impact based on the Risk Assessment
Matrix?
1 = low frequency (rare)
3 = intermediate frequency (likely)
5 = high frequency (very likely)
 Public interest/perception (P) - What is the rating of public perception and interest in proposed
project and impact based on consultation with stakeholders.
1 = low interest/perception
3 = intermediate interest/perception
5 = high interest/perception
 Importance of affected environmental components and impacts (I) - what is the rating of
importance based on consensus of opinion?
1 = low
3 = intermediate
5 = high

This approach was adopted considering its interactive and descriptive analysis of the relationship
between the proposed project activities and the ecosystem components. The potential impacts of
the proposed independent power project in OML 58 are presented in Table 5.1.

The method for evaluating the column overall ranking is not explained.

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