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OKIPP Limited ESMP Summary

ENVIRONMENTAL & SOCIAL

MANAGEMENT PLAN (ESMP)

OF

OKIPP Limited

ITU LOCAL GOVERNMENT AREA,

AKWA IBOM STATE

OCTOBER 2013


Project Title: Oku-Iboku Pulp & Paper Project Project Number: P-NG-AAG-002. Country: Nigeria

Department: OPSM Division: OPSM2

1. INTRODUCTION

1.1 Background:

The implementation of the Federal Government’s import substitution policy which started from

independence coupled with the increasing demand for paper and paper products in the country

brought about the Government’s decision to expand its industrial base to include pulp and

paper, to develop Gmelina plantations and ultimately to establish domestic integrated pulp and

paper mills in three locations in the country, namely:

The Nigerian National Paper Manufacturing Company Limited at Iwopin in Ogun State

to produce bond paper

The Nigerian Paper milling Jebba, Kwara State to produce Kraft paper and

The Nigerian Newsprint Manufacturing Company Limited in Oku-Iboku in Akwa Ibom

State to produce newsprint paper

The three mills were to complement each other in meeting the nation’s demand for paper and

paper products. The Nigerian Newsprint Manufacturing Company Limited, (NNMC), (now

OKIPP Limited) was incorporated in 1975 as a private limited liability company to produce

100,000 metric tons of finished newsprint per annum. It was the only newsprint manufacturing

company in the West and Central African sub region. The first of the mill’s two paper

machines was commissioned in 1986 and the second one a year later. During the eight (8)

years of its operation (1986 -1993), the mill produced a total of 163,684 metric tons of finished

newsprint as against the expected 800,000 metric tons based on the machines’ combined

installed capacity of 100,000 metric tons per annum. Prior to the shutdown of the mill in 1994,

NNMC exported newsprint paper to USA, Cameroon, Germany, Togo, Ghana, Zimbabwe.

Following the Federal Government’s decision to withdraw from direct participation in the

running of industries, Negris Investments Limited incorporated a new Company called OKIPP

(Oku-Iboku Pulp & Paper) Limited in 2008. Negris Group was established in 1980 and prides

itself as the foremost indigenous energy, oil and gas service company in Nigeria. Negris

mission is to provide services and products that enhance customers’ objectives while remaining

friendly to the environment.

1.2 Objectives:

The main objectives of the project are:

Rehabilitation of the existing assets and upgrading of critical areas of technology in the

company;

To boost demand for newsprint and papers for local printers for them to operate at

profitable levels;

To sustain the printing industry in Nigeria and West Africa; and

To provide support for the on-going Nigeria’s private-sector led growth;


2. PROJECT DESCRIPTION

The project entails the rehabilitation and modernisation of the OKIPP pulp and paper mill

assets to bring them up to modern international standard of operational efficiency, product

output quality and environmental impact. Once rehabilitated and modernised the mill will be

capable of producing a family of “Uncoated Mechanical” papers, including newsprint and

similar graphical grades. The rehabilitation and modernisation phase of the project is

scheduled to last for 18 months. At the end of it, OKIPP will recommence full time

production.

3. POLICY, LEGAL, ADMINISTRATIVE AND REGULATORY FRAMEWORK

In line with AfDB’s requirements the project was classified as category 2 but an ESIA study

was carried out in accordance with regulations, guidelines and standards of the Federal

Ministry of Environment (FMEnv), Akwa Ibom State legislations on the environment, all other

applicable national legislations, and Multilateral Environmental Agreements (MEAs) to which

Nigeria is a party; as well as lenders guidelines. Relevant legislation and other requirements are

given below. The environmental study was carried out in 2 seasons (wet and dry season) as

specified by the national EIA guidelines. The dry season sampling therefore took place

between the 17th

and 21st December 2012 and wet season sampling between the 18th and 20th

June 2013. The field work for the SIA was conducted at two times with the

scoping/community engaged exercise taking place from the 9th to 13th of December, 2012 and

the data collection from the 14th

to the 25th

of May, 2013. Field work was carried out to

objectively assess the environmental and social baseline characteristics of the proposed project

site as well as determine the sustainability of operations at the factory and also to comply with

national environmental regulations.

The main relevant piece of legislation is therefore the Environmental Impact Assessment (EIA)

Act (Act No. 86 of 1992) that makes EIA mandatory for all major public and private projects

in Nigeria. The EIA Act sets out to:

Consider the likely impacts and the extent of these impacts on the environment before

embarking on any project or activity;

Promote the implementation of appropriate policy in all federal lands consistent with all

laws and decision-making processes through which the goal of this Act may be

realized;

Encourage the development of procedures for information exchange, notification and

consultation between organizations and persons when the proposed activities are

likely to have significant environmental effects on boundary or trans-state or on the

environment of bordering towns and villages

Other legislation relevant to the project includes:

i) Federal Environmental Protection Agency Act No. 580/30 December 1988 (as

amended by Act 59 of 1992 and further amended by Act 14 of 1999)

ii) National Environmental Protection (Effluent Limitations) Regulation (S.1.8) 1991

mandates industries generating wastes to install antipollution and pollution

abatement equipment on site.


iii) National Environmental Protection Regulation (S.I.9) 1991regulates the release of

toxic substances.

iv) National Environmental Protection (Management of Solid Hazardous Wastes

Regulation (S.1.15) 1991spells out the requirements for groundwater protection,

surface impoundment, land treatment, waste piles, landfills, incinerators, etc. It also

describes the hazardous chemical products and dangerous waste constituents.

v) EIA Procedural and Sectoral Guidelines of the Federal Ministry of Environment

(FMEnv) 1995 as revised 2009

vi) Land Use Act of 1978

vii) Applicable international Environmental Statutory Limits/Standards

viii)Criminal Code that makes it an offence punishable with up to 6 months imprisonment

for "Any person who: Violates the atmosphere in any place so as to make it noxious to

the health of persons in general

ix) The Natural Resources Conservation Act 1989

x) Endangered Species (Control of International Trade and Traffic) Act 11 of 1985

xi) The National Parks Decree (Decree No 36 of 1991)

xii) The Akwa Ibom State Environmental Protection and Waste Management Agency Law

2000 that establishes the Akwa Ibom State Environmental Protection and Waste

Management Agency and mandates it to implement and enforce the state’s policies and

laws on environment and stipulates all major development projects in the State to be

subjected to EIA. It also makes EAR and EIA mandatory for all manufacturing

industries in the State.

xiii)National and relevant state Statutory Limits for Effluent and Gaseous Emissions

xiv) International Standards, Treaties and Conventions

xv) Convention on the Conservation of Migratory Species of Wild Animals

The lenders requirements such as the AfDB’s ESAP are also considered important and full

compliance with them is a priority.

4 MAJOR ENVIRONMENTAL AND SOCIAL IMPACTS

4.1 Health Impacts The social impact assessment (SIA) showed that the level of sanitation was satisfactory and

solid waste was managed by open burning and unregulated dumping. Domestic water quality is

fair to good and was sourced from the stream and boreholes. The Company has provided some

facilities including boreholes for supplying good water in some settlements, but these were no

longer functional according to the people consulted. Generally the perceived health status of

residents in the plantation areas was better than those in the mill area. Respiratory problems

like coughs and tuberculosis were more common in the mill area. The current project will

increase exposure to dust particles for communities during construction but overall dust, heat

and fumes hazards in the work environment will be reduced due to installation of modern

equipment. The Company will improve access to health care clinics particularly in the vicinity

of the mill.


4.2 Social Impacts

During the scoping exercise, eight villages from the same clan, were identified as those likely

to be directly affected by the activities of the OKIPP Mill. Of the four plantations in Cross

River State that will provide timber for OKIPP Ltd, the ESIA focused on Awi and Nsan.

Obom Itiat Edere was also included due to its history of conflict. The SIA found a number of

potential social impacts that are likely to result from the activities of the Company.

Most of the communities are quite small and are relatively socially homogeneous and the

majority of the residents are indigenes. The influx of workers and service providers will result

in more social diversity with the potential social problems of conflict and deviant behaviour.

This will require better security measures in the locality. OKIPP Ltd shall work with traditional

leaders and existing social groups in the area to ensure good relations, also including youth and

women as important stakeholders.

While nearly all of the respondents reported that they are Christians, traditional religious

worship is very strong with the evidence of many sacred sites and shrines. Many of these sites

of social significance including a cemetery, have been damaged or become inaccessible to the

local population as a result of the establishment of the mill and plantations. The residents have

strongly protested that there is need for relocating these sites so that they may have access to

them. The Company shall enter into dialogue with the local residents and facilitate the

relocation of some of the major sites. This will have a very positive effect upon the

relationship with the local population who will see the Company as responsive to their

requests.

The general impression of the local population is that the income generating activities that have

traditionally been relied upon, including farming, fishing and hunting, have been severely

affected by the activities originally of NNMC and now OKIPP Ltd. Providing alternative

activities, capacity building training or employment opportunities can lessen the effects of this

impact. These were generally considered the priority needs in the locality as determined by the

needs assessment. This is an area that OKIPP Ltd can significantly mitigate the potential

negative impacts of the Project. The influx of more money into the local economy will likely

have a positive impact upon the traders by having a higher demand for their products and more

customers with the attendant higher prices for their goods. However, it may negatively impact

upon the standard of living for other inhabitants. This was found to be the experience during

the earlier days of NNMC operations. Nevertheless, the cost of living in the area and the

potential to purchase needed goods and services shall be monitored to prevent escalation of

poverty in the area, particularly among socially marginalized groups.

The occurrence of conflict within or between communities is relatively uncommon. Although

not directly related to OKIPP Ltd, the most significant incident of conflict in the locality in

recent times has been the case of Obom - Itiat - Edere. Conflict can affect the activities in the

mill and plantation areas and OKIPP Ltd shall pay attention to relocation of their sacred sites;

provision of employment and facilities. Transportation networks will be altered as OKIPP Ltd

begins operations in earnest. At the present time, there is a lack of adequate transport services.

Many more cars and buses will begin to ply the roads in the mill area to transport workers,


trucks and lorries carrying timber logs and finished products will soon be common in both

areas. The poor state of the roads is an area where there will necessarily be improvements. The

Company shall embark on safe driving awareness campaigns.

The project may increase the frequency of many social vices in the host communities among

which are armed robbery, prostitution, HIV etc. In general, there are potentially several areas

of social impact some of which are mitigated through Corporate Social Responsibility efforts.

OKIPP will also establish a Grievance Resolution Mechanism with adequate representation of

all relevant stakeholders whereby the concerns of the local population can be addressed and the

Company’s position can also be fully understood.

4.3 Environmental Impacts

Significant negative environmental impact associated with the project site includes the

following: (i) The sub-soils within the premises of the Mill are poor earthing media, hence there is

need for subsoil treatment for enhanced conductivity and improved earthing capacity. (ii) The

overburden protective capacity is weak for the near-surface sand aquifer which makes it poorly

protected from surface sourced pollutants. Other impacts include i) increased traffic and

possibly accident (ii) robbery (iii) work site accident (iv) Damage to communication cables (v)

Injuries and death from falling objects (vi) Work site accidents (vii) disruption of roads and

motorways usage. The noise level in the communities was perceived by the respondents to be

low; although majority of them attributed the noise to automobiles others attributed the noise to

generators. However, noise from the boilers, generators, movement of trucks in and out of the

mill and plantation and cutting of Gmelina arborea in the plantation will increase the level of

noise within these areas. Incomplete combustion from the fossil fuels of vehicles and emissions

from the boilers and generators will also have impacts on the air quality.

Significant positive environmental impacts associated with the project pertain to generation of

employment opportunities and hence improvement in the economy and socio-economic status of

individuals. During maintenance, the company shall endeavour to dispose properly their used

oil to future cost of soil remediation and contamination of nearby surface water body. The

environmental impact indicators are easily observable parameters that will indicate

change/deviation, which can be used to monitor the various environmental components. Those

considered in this study are summarized in Table 1 below

Table 1: Environmental Components and Potential Impact Indicators

S/

N

Environmental

Components Impact Indicators

1 Air Quality/Noise

Suspended Particulate Matter(SPM),Nitrogen Oxides(NOX), Sulphur dioxide

(SOX),Carbon Monoxide(CO), Volatile Organic Compounds (VOCs),

Hydrocarbons (CxHy) and Noise Levels

2 Soil/Agriculture

Soil type, Soil pH, Total Organic Carbon (TOC), Soil nutrients, Total

Heterotrophic bacteria and fungi, Hydrocarbon Utilizing bacteria and fungi

and Coliform, Hydrocarbon Utilizer; topography

3 Surface Water

Quality

Dissolved and suspended solids, pH, Biochemical Oxygen Demand (BOD),

Chemical Oxygen Demand (COD), turbidity, toxicity,Lead(Pb),

Cadmium(Cd),Arsenic(As), Nickel(Ni), Iron(Fe),Mercury(Hg)

Magnesium(Mg) and Total Heterotrophic bacteria and fungi, Hydrocarbon


S/

N

Environmental

Components Impact Indicators

Utilizing bacteria and fungi and Coliform, Hydrocarbon Utilizer

4 Ground water

quality

Dissolved and Suspended solids, Turbidity, pH, BOD, COD, Toxicity, Pb,

Cd, As, Ni, Fe, Hg, Mg. and Total Heterotrophic bacteria and fungi,

Hydrocarbon Utilizing bacteria and fungi and Coliform, Hydrocarbon

Utilizer

5 Socio-

economic/Health

Needs and concern of host communities, perceived employment, income

level, health risks, waste streams, Handling, Treatment and disposal, etc.

Table 2: Identified Project Impacts of OKIPP Ltd

Impacts

Phase

Mo

bil

izat

ion

Co

nst

ruct

ion

Op

erat

ion

Dec

om

mis

sio

nin

g

Acceleration of erosion √

Acidification of soil and water √ √ √

Alteration of local topography √

Alteration of soil profile √

Armed robbers attacks √ √ √ √

Blockage of drainage pattern √ √

Blockage of roads/motorways √ √ √ √

Change in water quality √ √

Contamination of groundwater √ √

Contamination of surface water and soil √ √

Damage to communication cables √

Exposure to heat, light and radiation √ √

Impairment of air quality √ √ √ √

Increased demand on social infrastructure √ √ √

Increased surface water turbidity √ √

Increase in incidence of STI’s including HIV √ √

Increase in social vices √ √

Increased opportunity for business and employment √ √ √ √

Influx of migrant workers and camp-followers √ √

Injuries and death from falling objects √ √ √

Interference with road transportation √ √ √ √

Legal issues √ √ √

Loss of employment/ income √

Loss of biodiversity √ √

Noise and vibration nuisance √ √ √ √

Road traffic accidents √ √ √

Work site accidents √ √

4.5 Envisaged Sustainability

4.5.1 Economic and Commercial Sustainability Throughout the operational outcome period, the liquidated NNMC provided over 700 Nigerian

labour force and therefore restoration of this gigantic industrial system is envisaged to be

economically and commercially sustainable owing to the desirability of OKIPP Ltd who are in

anticipation to increased future production levels of the product. Market for the Nigeria


Newsprint paper already exists all over the world as the international community alone is ready

to make purchases of over 70% of Nigeria’s Newsprint paper product.

4.5.2 Technical Sustainability The environmental and social impact assessment requirements of OKIPP Mill is technically

sustainable because of the proven integrity of health, environment, safety, security and social

concerns of the waste and effluent management as well as disposal technology that shall be

adopted and the experience of OKIPP Ltd management in the application of this technology.

The maintenance of strict adherence to internationally and nationally acceptable production

and operation standards and codes of practice at all stages of development shall also assure

technical sustainability of the assessment. The following proved the technical sustainability of

the project.

4.5.3 Energy Efficiency: A fundamental part of the OKIPP Reactivation project is to utilise

every opportunity to improve on energy efficiency and environmental discharges by the

adoption of Best Available Technologies "BAT" wherever feasible and viable. This includes

major investments in several new, or enhanced, process technologies, alongside numerous

smaller process and machinery enhancements that will allow significant gains to be realised in

terms of energy efficiency and all discharges (solid, liquid and gaseous).

4.5.4 Climate Change: OKIPP Ltd is investing in many measures that result in reduced specific

consumption of energy by increases in generating and usage efficiencies. They include:

Switching from Low Pour Fuel Oil (LPFO) to natural gas for all power generation

(electricity, steam, compressed air)

Process energy consumption efficiency improvements in all high intensity manufacturing

areas, eg. primary pulping process, paper drying on paper machines, use of high efficiency

sectional drives.

5. ENHANCEMENT & MITIGATION MEASURES In order to preserve the present integrity of the environment, certain steps have been

recommended to mitigate or control the medium and high negative impacts identified in this

study. The control/mitigation measures have been based on the baseline conditions with

regards to the biophysical environment, socio-economic and health status of the host

communities. Also considered were the project activities and their envisaged impacts and

concerns of stakeholders during consultation meetings and socio-economic/health status of the

host communities. The mitigation measures proposed are in keeping with environmental laws

at National and State levels; FMEnv (formerly FEPA, 1991) regulations on Pulp and Paper and

waste Management; Akwa Ibom State Environmental Protection and Waste Management

Agency laws, Akwa Ibom State Ministry of Environment policies; Best Available Technology

for Sustainable Development; Social wellbeing; and Concerns of stakeholders. To successfully

mitigate all the social impact that may be associated with this project, it is important that as

OKIPP establishes a committee of local stakeholders to protect the interests of all concerned

persons / groups.


The protective capacity of the sub-soils overlying the upper sand aquifer is weak, hence the

groundwater system is not protected from pollutants directly discharged on bare ground

surface. Effluent shall not be discharged on bare ground. Paving throughout the mill and

establishing a network of drainage channels shall be done. Summarized in Table 3 below are

the detailed mitigation and enhancement measures identified and recommended to ameliorate

all the significant associated and potential impacts identified for the operation of OKIPP Mill

in Oku Iboku.

Table 3: Showing Mitigation Measures for the OKIPP project

Description of Impacts Mitigation/Control Measures by OKIPP

Road traffic accidents

create awareness amongst neighbours

shall adhere to its journey management policy

organize Defensive Driving Course (DDC) for all vehicle drivers

ensure that project vehicles are pre-mobilized;

maintain adequate first aid in all project vehicles;

use only trained personnel for specified jobs;

ensure that job hazard analysis are carried out;

ensure daily pep-talk on each day’s job

Armed robbers attack

engagement of private security agents

engagement of Police whenever materials are to be moved to site;

materials shall not be handled in a way to attract third party

cash shall not be paid on site without security arrangement and

cash shall not be transported to site without security arrangement

Increased opportunity for

business

OKIPP shall hire non-skilled labours from the community

Local contractors shall be involved

Blockage of roads /

motorways

minimize movement at the peak hours of the day

ensure that all traffic rules are obeyed by the drivers

Interference with road

transportation

minimize movement at the peak hours of the day

ensure that all traffic rules are obeyed by the drivers

Worksite accidents

awareness creation amongst communities on potential of increase traffic

compliance with company’s journey management policy

compensation for proven project-induced injuries, accidents and fatalities

enforcement of the use of PPEs at sites.

daily pep talk are conducted with job hazard analysis carried out

Acceleration of erosion OKIPP shall ensure that opened earth surfaces are properly covered

Contamination of

groundwater

All effluents shall be treated to regulatory limits before discharging into the

environment. OKIPP shall ensure that untreated effluents are not released into the

public drain; ETP is properly operated and maintained.

Damage to

communication cables All communication cable lines shall be properly protected

Exposure to heat, light

and radiation

The HSE personnel shall ensure workers and visitors to the Mill are kitted with

appropriate PPE

Impairment of air

quality

OKIPP shall ensure that only pre-mobed equipment are used; the use of all equipment

shall be controlled and that equipment engines are turned off when not in use

Injuries and death from

falling objects

Workers and visitors to site will be made to put on safety helmet

Noise and vibration

nuisance

OKIPP shall discuss precautions against noise with contractors; combustion engines

shall be fitted with effective silencers; there shall be regular maintenance of

machines; engines shall be switched off or reduced to idle when not in use; hearing


Description of Impacts Mitigation/Control Measures by OKIPP

protection devices (HPD) shall be provided for workers and visitors

Loss of

employment/Income

OKIPP shall support entrepreneurial skill development and opportunities for

community members to cushion the effect of reduction in economic/income

generating activities.

Lack of access to sites

of cultural significance

and social conflicts

Okipp shall have on going public consultations to understand challenges and put I

place a grievance mechanism to ensure all parties are not made worse off by the

project.

Incorporation of mitigation measures at all stages of project development and full

implementations / strict adherence to the designed ESMP will ensure an environmentally sound

project. Furthermore, OKIPP Ltd will implement an Environmental Management System

which will clearly define the responsibilities for all environmentally-relevant aspects in the

mill. OKIPP Ltd will train all employees, contractors and visitors to any of its operations on

SHE issues. This will include, but is not limited to; isolation procedures (steam, compressed

air, chemicals and electricity), safe systems of work, PPE, machinery guarding, interlocks and

safety devices, process safety through automation, testing and statutory compliance, etc.

OKIPP Ltd will have a validated Health & Safety policy, and a Health & Safety Manager, with

senior management level authority.

OKIPP shall have a process control optimisation to be able to reduce different pollutants

simultaneously and to maintain low emissions, improved process control and measurement.

OKIPP Ltd is investing heavily in Best Available Technology (BAT) process control and

measurement. The rehabilitation and modernisation aspects of the project are designed to

encompass modern safety systems as applied to the manufacturing process and machinery, and

the way both are operated. OKIPP Ltd is investing heavily in new process control and

automation systems (incorporating multiple safety alert, warning and automatic response

measures) in BAT for guards, interlocks and personnel safety. There will be efficient process

energy consumption in all high intensity manufacturing areas, e.g. primary pulping process,

paper drying on paper machines, use of high efficiency sectional drives.

6. COMPLEMENTARY INITIATIVES & CAPACITY BUILDING:

The Company has provided some facilities including boreholes for supplying good water in

some settlements, but these were no longer functioning, according to the people. OKIPP shall

monitor any facilities or services provided to the community in a participatory manner to

ensure that the community ‘takes ownership’ of the facilities and will take responsibility for

maintaining them. Generally the perceived health status of residents in the plantation areas was

better than those in the mill area and OKIPP will ensure there is a functional health centre in

this regard. OKIPP will raise awareness on health, safety and environmental issues and also

provide the training required for communities to ensure sustainability of the benefits realised as

a result of the OKIPP project.


7. MONITORING

Table 4: Monitoring and cost of implementing the ESMP

ENVIRONMENTAL

COMPONENT

INDICATOR

(Parameters to be

Monitored)

SAMPLING

LOCATION FREQUENCY

RESPONSIB

ILITY

COST

(N)

Air Quality

Suspended

Particulate Matter,

Carbon Monoxide

(CO), Methane

(CH4), Ammonia

(NH3), Sulphur

Dioxide (SO2),

Nitrogen Dioxide

(NO2), Hydrogen

Sulphide (H2S).

Mill and

Plantations Quarterly

OKIPP Ltd/

Environmental

Consultant

825,000.00

Noise Level

Noise

measurement at the

mill and

plantations

Mill and


825,000.00

Health and Safety Air quality, Noise

and Particulates

Mill and


750,000.00

Soil

Oil and Grease,

THC, physico-

chemical

properties, pH

Generator area Quarterly

1,500,000.00

Ground/Surface

Water

TDS, pH,

Conductivity,

BOD, heavy

metals, biological

and physico-

chemical

characteristics

Mill and

nearby surface

water

Monthly

550,000.00

Occupational Health

Records of

PPE issued to

staff

Fire equipment

on site

OKIPP staff

on-site annually

750,000.00

Socio-economics

(communities)

Population,

occupation,

education, health

status,

infrastructure,

perception about

the projects, etc

Immediate

community Every 3 years

750,000.00

Table 5: Waste Management Guideline Recommended for OKIPP Facility

N. WASTE CATEGORY HAZARD ORIGIN PREFERRED

DISPOSAL OPTION

1 Liquid waste Industrial Potential groundwater,

surface water & soil

contamination

Waste treatment

process

Chemical treatment

before discharge



DISPOSAL OPTION

(hydrocarbons metals)

2 Sludge Industrial Potential health risk,

Potential groundwater,


contamination (metals)

Waste treatment

process

Dewatered and burned

as an alternate

renewable energy

source, landfilled or

applied on land.

4 Wood yard

debris and

mill reject

Industrial Non-hazardous, Potential

surface water contamination

Wood yard

burned as fuel

6 Empty

drums

Industrial,

Hazardous

Depends on original

contents of drum

Packaging of

lubricating oil,

fuel oil and

corrosion

inhibition

chemicals

Shall be sold as scrap if

non-hazardous contents.

Approved washing and

recycling of resultant

plastics or metals for

hazardous content

7 Oil & fuel

filter

cartridges

Hazardous Potential groundwater,


contamination


Engine & rotating

equipment

Approved incineration;

landfill

8 Oily rags Industrial Potential groundwater &



Maintenance &

clean-up

operations

Approved incinerations;

landfill

9 Scrap

metals,

metal

chippings,

scrap cables

Industrial Non-hazardous Scrapped

equipment

Recycling

10 Medical

wastes

Hazardous Potential health risk Terminal Clinic

and first-acid

treatment

Incineration

11 Saver Pit

Wastes

(sediments)

Industrial Potential groundwater &


(hydrocarbons)

Routine cleaning

of saver pit

Approved incineration;

landfill

13 Chemicals Hazardous Type & concentration will

determine hazardous nature

Environmental, Health, or

safety

Containers from

Effluent

Treatment Plant

area

Material Safety Data

Sheet (MSDS) shall be

used to identify

particular chemicals

14 Contaminate

d debris &

soil

Industrial,

contamination

Potential groundwater

contamination

Oil & chemical

spills, clean-up

operations

Land treatment,

approved incineration

of landfill,

solidification

15 Domestic

waste

garbage

Domestic Attracts rodents; leachate

from landfill may cause

problems; furnes from

burning is a nuisance

Accommodation,

office, canteen,

worksite

Segregation and

Recycling of

recyclables e.g. plastics,

paper, glass and landfill

on non-recyclables

16 Batteries:

Lead-acid,

nickel-

cadmium

Hazardous Corrosive-health & safety,

lead or heavy metals may

cause contamination

environmental &health

Vehicles, portable

& emergency

electrical tools,

production &

transmission

facilities

Recycling



DISPOSAL OPTION

17 Spent

Lubricants

Hazardous Potential groundwater &



Engine & rotating

equipment

lubricating

systems, vehicles

Recycling, Approved

incineration

18 Methane gas Stationary

combustion

source

Fugitive

emission

Greenhouse effect Relief/Blow down

systems, values

from process

valves and flanges

Ambient air discharge

20 Non-

methane

hydrocarbon

s (VOCs)

Non-

combustion

source

emissions

Stratospheric ozone

depletion and formation of

photochemical smog. Acid

deposition potential and

increase in ground level

ozone concentrations

Valves,

relief/Blow down

systems

Ambient air discharge

21 Diesel

engine

exhaust

Stationary &

Mobile

combustion

sources

Similar to natural gas

exhaust hazard but higher

amount of toxic sulphur

dioxide gas with higher

contribution to damaging

acid deposition

Diesel generators

& boat engines

Discharge via roof

stacks, boat exhaust

pipes

8. REMEDIATION PLANS AFTER DE-COMMISSIONING/ CLOSURE/

ABANDONMENT

The specific duration fixed for the subsistence of the OKIPP facility is 25-30 years and then,

the Mill will need to decommission. The Oku Iboku Pulp and Paper Mill, as conceived, is not

expected to have any significant long-term negative effects on the environment, especially after

closure/de-commissioning. A number of safety measures/devices have been built into the Mill,

such that it will operate at minimum risk. However, the following measures will be planned for

implementation after closure/de-commissioning:

The buildings used for the Chip washing, Pulp and Paper manufacturing and the utilities block

shall be dismantled or transfered for other exercises and sold at scrap value;

Generators, boilers, other Mill facilities and equipment shall either be sold or transferred for

other uses;

Contaminated soils, where they occur, shall be restored, using various options such as

chemical and/or biological remediation;

All pits and excavations shall be reclaimed and re-vegetated;

Buildings used for administrative purposes shall be leased out or used for other productive

ventures;

Appropriate pension schemes shall be put in place for project workers so that they can have

something to fall back on if and when the Mill is closed/ de-commissioned.

It is expected that if these measures are implemented, an excellent site restoration after

closure/de-commissioning can be achieved.


9. PUBLIC CONSULTATIONS AND DISCLOSURE REQUIREMENTS

To capture and address issues and concerns of every stakeholder to this project, wide reaching

consultation was conducted. Stakeholder consultation with regard to starting up the mill is an

ongoing process. The principal objective is to acquire and disseminate information, identify

and address legislative, community, and environmental concerns associated with the

resuscitation of the mill.

9.1 Objectives of Consultation

Facilitate communications and understanding between the various stakeholders and the project

proponent;

Gain support and buy-in from all relevant stakeholders

Comply with mandatory statutory requirements

Identify key issues relevant to the Pulp and Paper Mill and with potential impacts

Avoid conflict with all stakeholders by addressing issues promptly

9.2 Identification and involvement of key stakeholders

Experience has shown that certain potentially contentious issues are better understood by the

public. In view of this a successful and engaging consultation began at the conceptual stage of

the project and this was sustained throughout the project life cycle. Negris Group initiated an

early consultation process with all the relevant parties, so as to ensure that all the issues of

concern are addressed prior to start-up of the Mill. The identified regulators are:

o Federal Ministry of Environment

o The Akwa Ibom Ministry of Environment

o The Akwa Ibom State Environmental Protection and Waste Management Agency

o Cross River Ministry of Environment

o Chairmen of Local Government Authorities overseeing the communities where the project

is located in Akwa Ibom and Cross River State

o Representatives of Community leaders and youths in areas likely to be affected by the

proposed project

o Representatives of community based organisations (CBOs) and Non-governmental

organisations (NGOs) in the project area.

These regulators were notified through “Letters of Intention”: to carry out the ESIA.

9.3 Stakeholders Issue:

Basically, the stated needs of the Community can be grouped into several main issues

including improved road networks to assist the transport of people and goods, educational

facilities and training opportunities both in the formal and informal sectors, up-grading of

health care services and facilities, job opportunities from the Company, enhanced economic

activities through market facilities and access to capital and improved relations and

communications between the Company and the Community. Generational differences indicate

that youth groups are more prominently concerned with employment and training since they

are largely the ones with limited alternatives. Gender differences are also apparent in the case

that women are more concerned with markets due to their roles and responsibilities.


In line with the Corporate Social Responsibility of OKIPP Ltd, there are numerous community

development projects that could be implemented to alleviate the sufferings of the people.

Obviously, OKIPP Ltd is unable to meet all of the requests of the many communities and

settlements in the area, but consideration of some of the priority needs would significantly

improve relations with the local population and enhance the corporate image of the Company.

Particularly for the communities that are close to the plant, much of their land has been taken

over and their livelihoods affected. OKIPP Ltd may look into the potential for introducing

alternative income-generating activities to replace those that are no longer productive. For

example, if hunting is no longer possible, rearing of grass-cutters and snails could be

introduced. Where natural fish ponds have been polluted, fish farming may provide a suitable

substitute. This would require training and provision of financial capital and/or materials for

take-off.

Through the ranking of the needs in this exercise, it was possible to prioritize the needs by the

people themselves to determine the listed needs that are the most crucial problems of the

people that need intervention. This can assist the Company to make informed choices of

community development needs that will be more appreciated and acceptable to the local

population.

10. ENVIRONMENTAL HAZARD MANAGEMENT

The most common - and preventable - disasters in the paper industry are caused by fires, water

leaks, power outages, IT virus attacks, premises liability issues and human errors. The

Management commitment and responsibility of OKIPP are detailed in its Health, Safety and

Environmental (HSE) policy. The company shall operate in strict compliance with all the

provisions of this HSE policy which specifies the need for adherence to national standards and

guidelines by every member of staff and contractors, no matter how stringent. The HSE policy

of OKIPP states that projects are planned and executed in a manner that achieves the

following:

Preserves the health, safety and security of its employees, the employees of OKIPP Ltd

contractors, and all members of the public who may be affected by OKIPP Ltd

operations;

Give equal opportunity to all gender

Preference shall be given to the locals in both skilled and unskilled areas of OKIPP Ltd

operations

Improve their CSR in the areas of Scholarships to schools of host communities,

donation of information and communication technology (ICT) to schools within the

communities

Training and re-training of members of staff

Minimizes the impact of its operations on the environment; and

Be sensitive to the needs and concerns of OKIPP Ltd host communities.

10.1 Recovery from a Disaster The key to recovering successfully from a disaster is to have a plan in place when the disaster

strikes -- a set of simple, effective guidelines and procedures for all people to follow. Human

beings often make inappropriate decisions during a crisis. Therefore OKIPP Ltd will prepare


and share with other stakeholders a plan for coping with most emergencies. The OKIPP

contingency will encompass these “worst case” assumptions:

10.2 The Goals of the OKIPP Disaster Recovery & Business Resumption Plan The three (3) primary goals of OKIPP’s disaster recovery and business resumption planning

are to:

10.2.1 Eliminate or reduce the potential for injuries or the loss of human life, damage to

facilities, and loss of assets and records. This requires a comprehensive assessment of each

department within the organisation, to insure that appropriate steps have been taken to:

o Minimise disruptions of services to OKIPP and its customers;

o Minimise financial loss;

o Provide for a timely resumption of operations in case of a disaster; and

o Reduce or limit exposure to potential liability claims filed against the organisation, and its

directors, officers and other personnel.

10.2.2. Immediately invoke the emergency provisions of OKIPP’s Recovery & Business

Resumption Plan to stabilise the effects of the disaster, allowing for appropriate

assessment and the beginning of recovery efforts. OKIPP Ltd will seek to minimise the

effects of the disaster and provide for the fastest possible recovery.

10.2.3 Implement the procedures contained in the OKIPP Disaster Recovery & Business

Resumption Plan according to the type and impact of the disaster. When we implement

these procedures, OKIPP will prioritise all recovery efforts as follows:

Employees & Host Communities: Not only must OKIPP Ltd help to ensure their

survival as a basic human right, but because of their anticipated performance in helping

other persons on or around OKIPP's premises when disaster strikes;

Customers: OKIPP Ltd must help to ensure the survival of or care for customers affected by

the disaster: physically, mentally, emotionally and financially;

Facilities: After ensuring the safety of employees, host communities and customers, where

possible, OKIPP Ltd will secure each facility as shelter for both people and assets;

Assets: Conducting a damage assessment will determine which assets have been destroyed,

which ones are at risk and what resources that remain; and

Records: Documenting the disaster and the actions taken by OKIPP's personnel -- when

combined with comprehensive photos and video of facilities that are obtained during routine

facility inspections will help assess losses and the actions taken to minimise such losses.

10.3 OKIPP Recovery & Business Resumption Plan Effectiveness To be effective and to remain in compliance with regulations, OKIPP's Disaster Recovery &

Business Resumption Plan will contain:

The OKIPP Ltd and Negris Group's philosophy, mission statement and goals regarding

disaster recovery and business resumption

Written and approved executive succession instructions


The appointment of a temporary Disaster Management Executive Committee for the term

of the emergency that is empowered to act in the absence of the organisation's Board of

Directors

Clearly defined guidelines and scope of all disaster recovery and business resumption

efforts, based upon a thorough risk-assessment.

Clearly defined duties, authorities and responsibilities for each employee classification,

with designated primary and alternate department leaders and staff personnel to manage

critical functions;

A business recovery plan for each branch, department, facility and function within OKIPP -

and for essential service providers

Designated and equipped sites for assembling personnel and for housing specific operations

A well-documented testing and evaluation process conducted at specified intervals - and at

least annually

A comprehensive training program for all personnel at all facilities, conducted at specified

intervals - at least annually - that may also include the:

o Identification and operation of utility shut-off devices;

o Location of emergency staging areas;

o Basic first aid and survival techniques; and

o Emergency responsibilities and re-assignment plans for all positions; and

o Written copies of the final “OKIPP Disaster Recovery & Business Resumption Plan”

distributed to divisional and department leaders - including a complete list of

appropriate emergency response agencies and facilities.

11. ESTIMATED COST

ESMP implementation cost is shown in Table 4 above and amounts to (NGN 5.95 Billion).

12. IMPLEMENTATION SCHEDULE AND REPORTING

In addition to the mitigation measures identified which OKIPP Ltd is committed to

implementing from the onset, other recommendations from the environmental assessment

include the need to: undertake monthly/ monitoring for atmospheric emissions during the

operational phase; monitoring the effects that all phases might have on the host population and

environment at large; undertake and determine the best decommissioning strategy toward the

end of the project; undertake regular audits to ascertain the environmental performance of the

paper mill; sustain continued consultation meeting with host communities and government

regulatory agencies, continue to regulate their carbon footprint and seek ways to gain carbon

credits from the effective sustenance of the plantations. OKIPP shall report twice a year to the

AfDB on ESMP compliance and to the authorities as per the relevant authorisation

requirements.


13. CONCLUSION

It can be concluded from this study that the overall long - term impact of the Mill will be

beneficial in reducing the dependency of the country on imported newsprint and papers;

enhancing industrial production and economic activities in Akwa Ibom State and Nigeria at

large; reducing unemployment rate in the country; helping to protect and promote government

Local Content policy. The short-term beneficial impact comprises temporary employment for

the local population during rehabilitation/reconstruction and operation phases of the project.

This study has demonstrated that the overall impacts associated with the project can be

managed within reasonable and acceptable limits.

14. CONTACTS:

i. Kurt Lonsway, Manager, Environment and Climate Change Division, African

Development Bank, BP 323, Tunis 1002, Tunisia. Email: [email protected]. Tel.: +216

7110 3313.

ii. Kelello Ntoampe, Environmentalist, ONEC3, African Development Bank, BP 323, Tunis

1002, Tunisia. Email: [email protected]. Tel.: +216 7110 2707.

iii. Zineb Zeryouhi, Investmet Officer, OPSM 2, African Development Bank, BP 323, Tunis

1002, Tunisia. [email protected] Tel.: +216 7110 1790.

environmental & social management plan (esmp) · in more social diversity with the potential...

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