Chapter 10 - Environmental Management Plan
Chapter 10 - Environmental Management Plan
Chapter 10 - Environmental Management Plan
ENVIRONMENTAL MANAGEMENT PLAN
10.1 Introduction
The Environmental Management System (EMS) is designed to provide a process to ensure
the Project’s compliance with the applicable national and international laws and
regulations.
This framework Environmental Management Plan (“EMP”) will require further
development to produce the final EMS for the construction and operation of the Plant.
The primary objectives of this EMS are as follows:
To establish minimum standards for an Environmental Management System for the Project
Provide a framework that can be customized into a site specific EMS following the
conclusion of the Project development but prior to commencement of construction
Provide an EMS framework that will facilitate ISO 14000 certification at the Project site, if
necessary
ISO 14001 provide guidelines that provides organizations with guidelines to develop
appropriate environmental management practices, and where appropriate seek
registration with a relevant certification establishment.
The following outline is based on the general requirements of an environmental
management plan for this Project consistent with the requirements under the ISO 14001
standard.
1. Environmental policy
2. Planning
• Environmental aspects
• Legal and other requirements
• Objectives and targets
• Environmental management program(s)
3. Implementation and operation
• Structure and responsibility
• Training, awareness and competence
• Communication
• Environment management system documentation
• Document control
• Operational control
• Emergency preparedness and response
4. Checking and corrective action
• Monitoring and measurement
• Non‐conformance and corrective and preventative action
• Records
• Environmental management system audit
5. Management review
Specific monitoring requirements are outlined in Chapter 11.
10.2 Key Elements of the EMS
The key elements of the EMS areas follows:
• Assessing environmental effects (environmental aspects)
• Compliance with laws / regulations (legal and other requirements)
• Setting environmental objectives and targets
• Environmental management program(s)
• Structure and responsibility
• Training, awareness and competence
• Document control
• Emergency preparedness
• Reporting
• Audit and management review.
The EPC Contractor will be primarily responsible for maintaining the EMS during
construction whilst the Chief Operating Officer of the Project Company will have primary
responsibility for maintaining the EMS during the operations phase.
10.2.1 Assessing Environmental Effects (Environmental Aspects)
This Environmental Impact Assessment comprises the environmental assessments that has
been carried out in relation to construction and operation (and future decommissioning)
activities at the Project site. The assessment covers:
• Air emissions;
• Water intake and discharge;
• Waste characterization and inventory;
• Aesthetics;
• Noise;
• Consumption of chemicals, energy and other raw materials; and
• Labour and social issues.
Please refer to Chapter 7 of this ESIA Report for detailed review of the specific construction
and operational impacts.
10.2.2 Compliance with Laws/Regulations
Approvals / permits / consents / licenses relating to the environment will be in place prior
to construction and operational phases. The “permits‐to‐construct” and the “permits‐to‐
operate” will be displayed at locations easily accessible to personnel operating at the Plant.
The approvals / permits / licenses will include the following:
• Land use permits;
• Planning permission;
• Environmental approvals (discharge to air, discharges to water, transport of waste,
etc.)
• Water intake permits; and
• Contract with special and approved for transport of hazardous material.
Securing the requisite approvals and permits will be the responsibility of the Project
Company. Should any other approvals or permits be required for new activities, these will
be obtained prior to the commencement of any such activities.
10.2.3 Environmental Compliance Targets and Objectives
There are a number of specific environmental objectives that relate to the construction and
operation of the plant. The primary environmental objectives are as follows:
• Design, construct and operate its facilities in a manner that protects human health
and minimizes the impact of its operations on the environment
• Strive for an injury‐free work force and minimize environmental impact through
implementation of programs in its facilities and the surrounding communities that
reduce risks to employees, neighbors, the public at large and the environment
• The Project Company and EPC Construction Contractor will encourage and promote
waste minimization, the sustainable use of natural resources, recycling, energy
efficiency, resource conservation and resource recovery
• The Project Company will actively participate with the state and national
governmental agencies to ensure that the development and implementation of
environmental policies, laws, regulations and practices serve the public interest and
are based on sound scientific judgment
• All employees are expected to work in a safe manner and comply with the company's
Environmental policies and procedures. The Project Company should promote a
culture that encourages each employee to be environmentally responsible.
The Project Company should develop and maintain written safety policies and programs to
address known hazards at the plant. The KNO has very well documented safety operating
procedures and manuals which the Project Company should replicate. Policy and program
effectiveness and compliance should be regularly assessed
One of the most important components of these management systems is the Environmental
Performance Review.
• The frequency of audits should be similar to the regime practiced at the KNO Plant
• Audit teams constituted by a multi disciplinary team including environmental
professional. Engineers to promote a critical approach to the audit process
• When an audit is completed, the auditors report the findings to the site
environmental management team and work with them to develop action plans to
correct any deficiencies identified
• It is anticipated that Department of Petroleum Resources (Nigeria) will carry out
regular inspections of the Plant to ensure compliance with environmental
regulations and permits.
10.2.4 Environmental Management Program
Specific environmental management programs and procedures will be in place prior to the
commencement of construction and operation of the Plant. Procedures will include:
• Effluent Monitoring Procedures
• Stack Emission Monitoring Procedures
• Solid Waste Management Program (disposal and reuse procedures
• Emergency Response Procedures
• Environmental and Security Management.
Detailed provisions will be issued with the EPC Contractor (for the construction phase)
prior to the start of construction. Detailed provisions for the operation phase will be issued
by the Project Company prior to the completion of commissioning/operation start.
The programs should be reviewed according to the frequency specified in the document
control system, or on an as‐required basis following any incident, or non‐compliance.
The solid waste management program is a key component of the environmental
management program and it is presented in the following section as an example of an
environmental management program.
Solid Waste Management Program
During both construction and operation phases, waste should be handled according to a
waste management plan to be completed by the EPC contractor (for the construction
phase) and the Project Company (for the operation phase) prior to the start of these
phases.
The ESIA outlines waste management system requirements for construction and operation
as follows:
• Individuals and the company must accept responsibility for waste generated
• Waste reduction at source, followed by recycling, reuse, or recovery are the preferred
options
• Where options other than disposal are not feasible, destruction or treatment to
render the waste non‐hazardous should be the practice
• If the hazard cannot be eliminated, the waste should be contained in a secure manner
and monitored to ensure it is not and will not be damaging the environment
• Wastes should be segregated and quantified so they can be effectively managed.
• The amount of waste disposed offsite will be kept to a minimum.
Hazardous Waste Management
Hazardous waste materials, such as catalysts, will be handed back to the suppliers for
specialist disposal. All hazardous waste shipped from site will be subject to a waste
manifest to track generation, transportation through licensed and approved contractors.
NonHazardous Waste Management
Non‐hazardous industrial solid waste shall be stored in collection containers located within
the plant site and will be appropriately identified with markings. These waste materials
will be frequently removed in accordance with an agreed schedule by an approved and
licensed contractor. A waste handling program should exist for all non‐hazardous waste
steams in order to avoid waste accumulation.
The monitoring program will ensure proper implementation of the management plan.
Solid non‐hazardous waste quantities and the location of (government approved) final
disposal sites will be documented and the documentation kept for a minimum of 10 years.
10.2.5 Structure and responsibility
• All personnel working at the plant must be aware of their environmental
responsibilities under the relevant national and international legislation, and all EPC
contractors and operational staff members and contractors must undergo the
Induction/Orientation Program, which should include a section on Environmental
Awareness.
• Each Supervisor is responsible for the management of environmental issues in their
respective sections
• The EPC contractor (during the construction phase) and the Plant Management
(during the operation phase) will oversee the waste management system and find
efficient ways to minimize the waste produced.
• The EPC contractor (during the construction phase) and the Plant Management
(during the operation phase) are responsible for the co‐ordination of the
Environmental Management System.
• The EPC contractor (during the construction phase) and the Plant Management
(during the operation phase) should have the overall responsibility for
environmental performance at the site and should be required to assign dedicated
resources to coordinate all aspects of the Environmental Management System.
10.2.6 Training, awareness and competence
Training of personnel to ensure awareness and knowledge of the relevant EHS provisions
should be mandatory. The training program should cover:
• Fundamental understanding of the process plant operations
• Security of operations
• Incident Reporting
• Emergency Response and Notification
• Environmental Protection
• Site Hazards
• Personal Protective Equipment
• General Safety Rules & Safety Program
• Work Permit System/ Hazard Identification.
10.2.7 Document Control
Documentation and records system is central to the implementation of the EMS. The KNO
has developed and operated a very effective and sophisticated documentation system
which should be replicated by the Project following relocation of the process plant. The
documentation system will include:
• Plant Operations manuals (KNO Plants 4,5 and 6 operations manuals updated to
reflect conditions at the relocated plant)
• Compliance and monitoring records and reporting based on KNO format
• Incident reporting based on KNO format
• Training manuals (KNO Plants 4,5 and 6 training manuals updated to reflect
conditions at the relocated plant)
• Training records
• Project records – building on KNO Plants 4,5 and 6 project records
• Materials Management System.
This document describes the different types of records systems for environmental
management at the site.
10.2.8 Emergency Procedures
Specific emergency procedures must be developed by the EPC Contractor (for the
construction phase) and the Project Company (for the operation phase) prior to the
commencement of these phases. These procedures govern any emergency incidents at the
Project site such as spills, fires, gas leaks etc. Emergency Response procedures should
cover all anticipated emergency incidents.
10.2.9 Reporting
Full and detailed logs of the following incidents must be recorded:
• environmental limits breaches
• all major incidents.
In addition, all regulatory reporting and a full comprehensive annual EHS report should be
included in the financial statements of the Project Company.
10.2.10 Auditing and Management Review
Auditing is an important component of the Environmental Management Systems consistent
with ISO 14001. The audit of the EMS should be undertaken annually and should cover:
Verification of ongoing conformance with to all applicable laws and regulations
Confirmation of the continued efficacy of management systems to ensure compliance with
the applicable environmental standards
Identification of actual and/or potential environmental risks
The audit process will also assist management in identifying and prioritizing activities to
enhance environmental compliance.
10.3 Occupational Health and Safety & Community Health and Safety
The Project Company will implement all reasonable precautions to protect the health and
safety of its workers. Although this will primarily apply during the operations phase, the
Project Company will also ensure that all contractors and sub‐contractors employed at the
Project site during the construction phase will put in place occupational health and safety
policies to protect their workers.
The Project has been designed and located to be isolated from the community so the
provisions usually required for plants located close to communities would be limited for
this Project.
The emphasis should be placed on instituting preventive and protective measures in the
following order of priority:
1. Eliminating the hazard such as using less hazardous chemicals wherever possible
2. Controlling the hazard primarily through the use of engineering control measures
3. Minimizing the hazard through the design and use of safe work systems such as
training safe work procedures, lock‐out and tag‐out
4. Providing appropriate personal protective equipment (“PPE”).
Facility Design and Operation
1. Integrity of Workplace Structures – the plant buildings will be built and designed to be
structurally sound, fire‐resistant and noise‐absorbing materials will be used for
cladding on ceilings and walls, wherever possible, the large rotating equipment will
be relocated from KNO in their dedicated modular buildings
2. Standard Operating Procedures (“SOPs”) ‐ will be designed for emergency evacuations
and practice drills will undertaken, at least, annually
3. Workspace and Emergency Exits – adequate space will be provided for each worker,
the number and capacity of emergency exits will be sufficient for the orderly
evacuation of the maximum number of people and exits must be clearly marked to
be visible in total darkness
4. Fire precautions – the plant will be designed to minimize fire incidents through the
application of the relevant fire codes, fire detectors, alarm systems and fire‐fighting
equipment will be installed, as standard
5. Lavatories and showers – adequate facilities will be installed consistent with the
number of workers expected to work at the plant
6. Lighting – the plant will be designed to maximize natural lighting and emergency
lighting will be installed with automatic activation in the event of failure of the
principal artificial light source
7. Safe Access – passageways for pedestrians and vehicles within the plant battery limits
will be segregated for safe and easy access, equipment requiring servicing will be
unobstructed and unrestricted for ready access.
8. First Aid and medical facilities – eye wash stations and well equipped first‐aid stations
will be provided throughout the Plant. A medical facility capable of treating trauma
and serious illnesses up to the point of transfer to hospital will be provided within
the plant battery limits
9. Air Supply – sufficient fresh air should be supplied for indoor and confined work
spaces
10. Work environment temperature – the temperature in work, rest room and other
facilities will be maintained at levels appropriate for the facility during service
hours.
Communication and Training
1. OHS Training – will be provided to all new employees to cover basic site rules, basic
hazard awareness, safe work practices, personal protection and preventing injuries
to other employees
2. Visitor Orientation – a visitor orientation and control program will be established to
ensure visitors do not enter hazard areas unescorted
3. New employee and contractor training – all new employees and contractors will
receive detailed training and information prior to working at the plant
4. Area signage – hazardous areas (electrical rooms, compressor rooms etc), emergency
exits etc should be marked appropriately
5. Hazard code communication – copies of hazard coding system should be posted
outside the facility, at emergency entrance doors and fire emergency connection
systems. Information regarding the types of hazardous materials stored, handled or
used at the facility should be shared proactively with emergency personnel and
security personnel.
Physical Hazards
1. Rotating and moving equipment – the KNO rotating equipment have been designed to
eliminate trap hazards and ensure that operators are kept out of harm’s way during
normal operating conditions. Guards should be designed and installed to conform
with appropriate machine safety standards. The requisite turning off,
disconnecting, isolating and de‐energizing (Locked Out and Tagged Out) procedures
will be adopted
2. Noise – no employee will be exposed to noise levels greater than 85 dB(A) for a
duration of more than 8 hours per day without hearing protection and no
unprotected ear will be exposed to a peak sound pressure level of 140 dB(C). The
use of hearing protection will be actively enforced. The buildings design will
incorporate the use of acoustic insulating materials where feasible
3. Vibration – workers exposure to vibration from hand and power tools and large
equipment will be controlled through equipment selection, installation of vibration
dampening pads and limiting the duration of exposure
4. Electrical – the plant will adopt the appropriate electrical safety measures for a
facility of this nature to include marking all energized electrical devices with
warning lights, locking‐out and tagging‐out all devices during service or
maintenance etc
5. Eye Hazards – the use of machine guards or splash shields and/or safety glasses or
face shields (as appropriate) will be mandatory
6. Welding/Hot Work – the use of proper eye protection such as welder goggles and
barrier screens will be mandatory. Hot work procedures will form an integral part
of the Standard Operating Procedures for the plant.
7. Industrial Vehicle Driving and Site Traffic – right‐of‐way, site speed limits etc will be
clearly established to control site traffic. Drivers will undergo training and licensing
as well as frequent basic medical surveillance
Chemical Hazards
1. Air Quality – air quality will be regularly monitored consistent with the IFC guidelines
outlined in Section 2
2. Fire and Explosions – prevention and control strategies for fires and explosions are
outlined in Section 4.4
3. Asbestos – Agrium have confirmed that there is no residual asbestos containing
materials in KNO plants 4, 5 and 6. The Functional Design Specification for the EPC
Contractor prohibits the use of asbestos for the relocated plant construction.
Biological Hazards
1. Work places with occupational and natural exposure to ionizing radiation will be
established and operated inn accordance with the appropriate international
standards and guidelines
2. Exposure to non‐ionizing radiation (such as static magnetic fields, static electric
fields, radio frequency, microwave radiation, light and near‐infrared radiation and
ultraviolet radiation) will be controlled to internally recommended limits.
Communication Systems
1. Alarm bells, visual alarms will be used to alert workers and emergency services to an
emergency
2. Alarm and warning systems will be tested at least annually
3. Plans and measures will be implemented to communicate a potential emergency to
the community if the community is at risk from such potential emergency
4. Emergency information will be communicated to the media through trained local
spokesperson and via formal press releases with accurate information and
appropriate level of detail for the emergency.
Hazardous Material Release Mitigation, Implementation Strategies and Emergency
Response Plan
Strategy 1: Promote public awareness of potential hazards associated with handling of toxic
and hazardous substances.
Implementation Actions
• Cooperate with the local community, Ikpobha‐Okha local government, Edo State
and federal agencies to develop and disseminate information about the location,
types and amounts of hazardous substances to be handled by the plant.
• Communicate Emergency Response Plan to the local community, Ikpobha‐Okha
local government, Edo State and federal agencies with particular emphasis on
hazardous material spill, fire and explosion.
Strategy 2. Promote public knowledge of how to react to accidental hazardous material
release, plant fire and explosions
Implementation Actions
• Develop public education program to teach plant staff and the community about
sheltering in place and developed emergency preparedness plans and kits.
• Develop evacuation plans for all areas within the plant and the potentially impacted
community areas and provide public education about where to find evacuation
information.
Strategy 3. Develop emergency response capabilities in the event of an accidental discharge of
toxic or hazardous substances.
Implementation Actions
• Support training programs for first responders particularly process plant first aiders
and the plant fire departments.
• The emergency response team should be capable of responding at the technician
level, with support from additional responders trained to operations level.
• Conduct a hazardous materials risk analysis specific to the materials used and
transported within and outside the plant.
• The construction phase emergency response plan will form an integral part of the
Construction Phase Site Rules to be completed prior to Construction Start – this
document will be issued to and adhered to by all the contractors operating at the site.
• The operations phase emergency response plan will form integral part of the Plant
Operations and Maintenance Manual to be completed prior to Plant Commissioning –
this document will be issued to and adhered to by all the staff working at the plant.