PCB Management Project, Nigeria

PCB Management Project, NigeriaEnvironmental and Social Management

Framework (ESMF)[Type the abstract of the document here. The abstract is typically a short summary of the contents of the document. Type the abstract of the document here. The abstract is typically a short summary of the contents of the document.]

2010

HOSPITALIA CONSULTAIRE 1/1/2010

E2456

PCB Management Project, Nigeria- WB-GEF 2010

Contents

CHAPTER1: INTRODUCTION.....................................................................................................4

BACKGOUND.......................................................................................................................................

1.1 Initiative.................................................................................................................................12

1.2 World Bank EA requirements and compliance.....................................................................12

1.3 Key Issues..............................................................................................................................13

1.4 PCB Management in Nigeria.................................................................................................13

1.5 Policy, Legislation and Guidelines........................................................................................15

1.6 National Laws and Regulations.............................................................................................16

1.7 International Laws and Regulations......................................................................................18

World Bank Guidelines on Environmental Assessment {EA} (1991)...........................................18

CHAPTER 2: PROJECT DESCRIPTION......................................................................................26

2.1 Project country-Nigeria Overview.........................................................................................26

2.2 Project Scope.........................................................................................................................28

2.3 Project Objectives..................................................................................................................28

2.4 Description of the Proposed PCBs Management Project......................................................28

2.4.1 Project Components.....................................................................................................28

CHAPTER 3: APPROACH TO ENVIRONMENTAL AND SOCIAL ASSESSMENT................31

3.1 Environment and Social Safeguard Policies..........................................................................31

3.2 Typical information provided in the EA document...............................................................31

3.3 Activities Covered under the ESMF......................................................................................31

3.4 ESA Instruments required for each Component....................................................................33

CHAPTER 4: POTENTIAL ENVIRONMENTAL IMPACTS OF EACH COMPONENT................36

4.1 Capacity Building for PCB Management..............................................................................36

4.2 Design, development and implementation of environmentally sound management (ESM) for online and offline electrical equipment and potentially contaminated sites................................36

4.3 Baseline national inventory of PCBs and PCB containing equipment, and development of a national PCB management plan.........................................................................................................40

4.4 Project Management and Monitoring and Evaluation...........................................................41

CHAPTER 5: PROJECT-RELATED MITIGATION STRATEGY...............................................42

5.1 Component 1: Capacity Building for PCBs Management.....................................................42

5.2 Component 2: Design, Development and Implementation of Environmentally Sound Management (ESM) for Online and Offline Electrical Equipment and Potentially Contaminated Sites 42

5.2.1 Abstract of Mitigation measures by sub-component.........................................................42

H O S P I L A T I A C O N S U L T A I R E Page 69


5.2.2 Development of Site- Specific Safety Management Plans for Interim Storage Sites/Locations............................................................................................................................45

5.3 Component 3: Baseline national inventory of PCBs and PCB containing equipment, and development of a national PCB management plan............................................................................46

5.4 Component 4: Project Management and Monitoring and evaluation...................................46

CHAPTER 6: PCBs MANAGEMENT PROJECT – ENVIRONMENTAL ASSESSMENT.........47

6.1 Project Alternatives................................................................................................................47

6.2 Impact Assessment................................................................................................................51

6.2.1 Impact/Hazard Prediction Methodology......................................................................51

6.2.2 Rating of Impacts/Hazard............................................................................................51

6.2.3 Determination of Associated and Potential Impacts..........................................................54

CHAPTER 7: OVERVIEW OF ENVIRONMENTAL ASSESSMENT PROCESS.......................60

7.1 Stakeholder Participation............................................................................................................60

7.2 Public Consultation and Disclosure............................................................................................62

7.2.1 Institutional Arrangement:.......................................................................................................... 62

7.2.2 Institutional Capacity for Environmental Management. .........................................................62

7.2.3 Monitoring and Evaluation:........................................................................................................63

7.2.4 Training..............................................................................................................................63

Chapter 8: COSTS AND BUDGETING FOR ESMF IMPLEMENTATION...............................65



Executive Summary

Following on efforts on the environmentally sound management of POPs and PCBs in particular, as part of its National Implementation Plan (NIP) on POPs, and in part fulfilment of its obligations towards the Stockholm Convention on Persistent Organic Pollutants, the Federal Government of Nigeria, through the facilitation of the World Bank, received funding from the Government of Canada to carry out two key PCBs studies:

- Baseline National Inventory of PCBs and PCB-Containing Equipment in Nigeria (2008), and,

- Location and Assessment of the Status of PCB Containing Equipment in Power Holding Facilities all over Nigeria Consistent with the Requirements of the Stockholm Convention (2009)

With findings from the two projects, the Federal Government of Nigeria with the assistance of the World Bank as an implementing agency of GEF is in the process of developing a PCB Management Project for Nigeria, which will entail safe and environmentally sound management of PCBs, PCB containing equipment and wastes.

This project has four (4) major components:

a) Component 1: Capacity Building for PCB Management

b) Component 2: Design, development and implementation of environmentally sound management (ESM) for online and offline electrical equipment and potentially contaminated sites

c) Component 3: Baseline national inventory of PCBs and PCB containing equipment, and development of a national PCB management plan

d) Component 4: Project management and Monitoring and Evaluation

This project falls into Environmental Assessment Category B as no significant adverse long term impacts are anticipated. Indeed no long term or cumulative adverse impacts were identified during the preparation of the safeguard instrument – Environmental and Social Management Framework (ESMF). The project will not fund activities that would cause any form of land acquisition or restriction of access to sources of livelihoods. The choice of ESMF is appropriate as the exact location of interim storage locations and impacts are not known at this phase of project preparation. This ESMF provides insights and mechanism to identify potential significant adverse impacts beyond the generic ones for which standard mitigation measures are built in and applied during implementation. Specifically, the potential significant environmental and social impacts identified by the ESMF are those associated with (i) Inventory and labelling of PCBs and PCB containing equipment; (ii) Transportation to designated interim storage facilities; (iii) cleaning up of PCB contaminated sites including soil and water; and (iv) PCB storage and management at designated facilities



and (v) and enhancement of interim storage locations. Environmental and social protection clauses will be included in the bidding and contract documents as the case may be.

Further, the ESMF also provides guidelines for preparing an Environmental Management Plan (EMP) or an Environmental Impact Assessment (EIA) as may be applicable during project implementation. The project will have both beneficial and negative impacts on the physical, biological and social environment. Both these impacts and their associated mitigation measures are discussed as well as the institutional mechanisms used to implement the ESMF. Roles and responsibilities are clearly stated, including capacity building efforts for participating stakeholders in the Project. The monitoring plan defines roles and responsibilities for routine monitoring of the project. Routine monitoring focuses mainly on construction supervision and health, safety and environmental (HSE) protection awareness. Routine monitoring requirements are defined according to potential impacts and recommended mitigation measures. Finally, a consultation plan was developed to provide a framework for achieving effective stakeholder participation in the project. The sum of US$ 425.000 was estimated as the cost of implementing the ESMF.



CHAPTER1 : INTRODUCTION

BACKGOUND The Stockholm Convention

The Stockholm Convention is a global treaty to protect human health and the environment from persistent organic pollutants (POPs). POPs are chemicals that remain intact in the environment for long periods, become widely distributed geographically, accumulate in the fatty tissue of living organisms and are toxic to humans and wildlife. POPs circulate globally and can cause damage wherever they are found. In implementing the Convention, Governments are required to take measures to eliminate or reduce the release of POPs into the environment. Over 150 countries have signed the Convention and it entered into force, on 17th May 2004, 90 days after the ratification by the fiftieth country.

The Stockholm Convention is focused on eliminating or reducing releases of 12 POPs originally (the so-called "Dirty Dozen"). In 2009, nine new chemicals were added to the least at COP-4. Signatories are required to reduce the risks to human health and the environment arising from their release. Enlisted parties are required to take measures (legal and/or administrative) to eliminate or heavily restrict the production and use of POPs, and to minimize their unintentional production and release into the environment. The convention also, channels resources into cleaning up the existing stockpiles and dumps of POPs that litter the world's landscape, and thus, targets a future free of dangerous chemicals.

Five essential parts to the Stockholm Convention include:

Eliminate dangerous POPs Support the transition to safer alternatives

Target additional POPs for action

Cleanup old stockpiles and equipment containing POPs

Work together for a POPs-free future

The Stockholm Convention on POPs makes allowance for further chemicals to be qualified as POPs (as was recently done with the nine new POPs).

The “Dirty Dozen” POPs listed in the original Stockholm Convention


http://www.unido.org/index.php?id=5167

http://www.unido.org/index.php?id=5167

http://www.pops.int/


Listed on Annex A for elimination:

Aldrin

Chlordane

Dieldrin

Endrin

Heptachlor

Hexachlorobenzene (HCB)

Mirex

Toxaphene

Polychlorinated biphenyls (PCBs)

Listed on Annex B for elimination

DDT (with specific exemption for disease vector control, and as a site-limited, closed system intermediate)

Listed on Annex C to reduce or eliminate releases

Polychlorinated dioxins

Polychlorinated furans

Hexachlorobenzene (HCB)

Polychlorinated biphenyls (PCBs)

The fourth Conference of the Parties (COP‐4) of the Stockholm Convention on Persistent Organic Pollutants (POPs) reached consensus to add nine new POPs to the treaty’s original "Dirty Dozen."

The nine “new” POPs added

Listed on Annex A for elimination;

Alpha hexachlorocyclohexane (unintended byproduct of lindane manufacture)

Beta hexachlorocyclohexane (unintended byproduct of lindane manufacture)



Commercial octaBDE - hexabromodiphenyl ether and heptabromodiphenyl ether – (used as a flame retardant)

Commercial pentaBDE - tetrabromodiphenyl ether and pentabromodiphenyl ether - (used as a flame retardant)

Chlordecone (an agricultural pesticide)

Hexabromobiphenyl (a flame retardant)

Lindane (used in creams for treatment of head lice; previously used in agriculture -"specific exemption" for pharmaceutical use to control head lice and scabies)

Pentachlorobenzene (used as a dyestuff carrier, fungicide, and a flame retardant)

Listed on Annex B for restriction:

PFOS perfluorooctane sulfonic acid, its salts and perfluorooctane sulfonyl fluoride (with specific exemptions for: photo masks in the semiconductor and liquid crystal display (LCD) industries, metal plating, electric and electronic parts for some printers and colour copiers, insecticides for certain fire ants and termites, oil production, carpets, leather and apparel, textiles and upholstery, paper and packaging, coatings and coating additives, rubber and plastics; and "acceptable purposes": photo-imaging, photo-resist and anti reflective coatings for semiconductors, etching agents for compound semiconductor and ceramic filter, aviation hydraulic fluids, metal plating in closed-loop systems, certain medical devices, fire-fighting foams, insect bait for control of certain leaf-cutting ants).

Polychlorinated Biphenyls (PCBs)

Composition of PCBs

PCBs are aromatic chemicals, manufactured by the chlorination of two phenyl rings. The chemical formula is C12H10-nCln, where the chlorine number ranges from 1 to 10. Theoretically, there can be as many as 209 congeners in the PCB family, although only 130 are generally found to occur in commercial products. They are generally, structurally similar organic chemicals, ranging from oily liquids to waxy solids and, were generally sold in mixtures of a number of different isomers and congeners. Individual congeners are colourless, often crystalline compounds, but commercial PCB mixes form yellow oily liquids to resins, with properties varying with the mixes.

Polychlorinated Biphenyls (PCBs) are banned worldwide due to their ability to bioaccumulate, persistence in the environment, toxicity and carcinogenicity. PCBs are man-



made chlorinated aromatic hydrocarbons, which have been used as dielectrics in transformers & capacitors, carbon-less copy paper, fire retardants, and other applications that required products with high heat resistance, elasticity, and durability (such as in hydraulic systems, lubricating oils), and as plasticizers and solvents in paints and plastics. Their manufacture and distribution has been banned since 1978. They are also generated and released into the environment as waste by-products of chemical manufacturing and incineration.

The physicochemical properties of PCBs are responsible for their behaviour in the environment – low solubility in water and solubility in organic matter, low vapour pressure, high degree of chemical stability under normal conditions, (19 PCBs are stable at room temperature), lipophilic (high fat solubility) and thus very high bioaccumulation factor (BCF). These properties govern PCB fate and transport in the environment – this means that metabolism in an organism is very slow; therefore bioaccumulation occurs in the adipose (fatty) tissue.

Toxicology

PCBs are classified as both toxic chemicals and carcinogens for humans as well as other animals, with 12 of the 209 congeners considered dioxin-like. A further 9 are considered highly toxic, and 25 have been commonly identified bio-accumulated in milk or fish. Contamination of vegetation is generally due to adsorption from contaminated soil onto the outer surface of the plant. There is no evidence for PCBs being particularly phytotoxic (except for a slowing of growth at very high concentrations); however, this is an uptake route for herbivorous animals, and thus to higher mammals. Aquatic life is especially prone to bioaccumulation, with the PCB concentrations increasing up the food chain.

Human toxic experiences with PCBs have had to do with commercial mixes rather than individual congeners. Signs and symptoms of acute PCBs toxicity include chloracne, skin pigmentation and death. Chronic symptoms include liver damage, respiratory problems, CNS damage and developmental abnormalities in foetuses and newborns.



The past report on the partial inventory of PCBs in Nigeria (2008/2009) showed that the country have high amounts of PCBs-contaminated equipment and oil in various Power Holding Company of Nigeria (PHCN) facilities around the country, thereby requiring the establishment and adoption of an environmentally sound management (ESM) approach. Many of the equipment inventoried where found to be out of use but still in place, or in storage, and poorly managed.

Also, following the outcome of the recent study “Location and Assessment of the Status of PCBs-containing Equipment in PHCN facilities all over Nigeria” where all PHCN Generation, Transmission and Distribution facilities around the country were successfully located and visited. In the course of the study it was discovered that many of the facilities contained PCBs contaminated equipment, oil in drums/tanks, and a lot of sites had oil spills on them. The project was able to establish the following:

The facilities locations and their GPS Coordinates Estimation of the quantities of disused oils in the sites Estimation of the quantities and weight of disused equipment in the sites Estimation of the size of contaminated soils for each location Field analysis of oil for PCBs contamination Identification of water bodies around the sites Samples collection for hydro-geological analysis Risk assessments for environmental and health impacts of the sites

The project report issued the below stated recommendations:

1. To achieve sound environmental management of PCBs-contaminated sites, there is a need for a comprehensive evaluation of the broad range of risks (social, cultural, economic, health and ecological) posed by the sites and recommendation of appropriate remedial actions.

2. There is an urgent need for an awareness creation and training program for all administrative and technical personnel in all generating, transmission, distribution and work shop facilities of PHCN all over the country on PCB, and its environmentally sound management.

3. A need for the procurement and provision of analytical capabilities in PHCN facilities for the screening of PCB in transformer oil.

4. Stakeholder and public awareness creation on the environmental and public health impacts of Hazardous chemicals and POPs.

5. Interim storage of potentially PCB-containing equipment and oil should be on hard-standing, impermeable base, coated with a sealant. The areas storing drums and equipment containing PCBs should be bonded and all stored items clearly labelled.



6. PHCN technical personnel especially in the transformer repair facilities should be made to stop disposal and pouring of oils on the ground and into water bodies

7. Long-term monitoring and evaluation of potentially PCBs-contaminated sites should be conducted to determine management approach, evaluate the effectiveness of the chosen management option, and ensure adequate, continuous protection of humans and the environment.

8. Establishment of institutional controls (interim controls), implemented to control exposure to contaminants and reduce risk to humans and the environment until risks can be reduced to acceptable levels by other management options - (There are four general categories of institutional controls: government controls; proprietary controls; enforcement tools with institutional-control components; and informational devices).

9. Increase regularity for Environmental Impact Assessment (EIA) for potentially contaminated sites.

10. There is a need for the construction of facilities for temporary storage of PCB-containing waste (including suitable drums and steel trays).

11. Preparation and conduct of a full inventory of PCB-containing equipment with labelling and localization.

12. Preparation of guidelines for decontamination of equipment using BAT & BEP.

13. Determination of the price for transport, temporary storage and final disposal( including comparison of disposal technologies)

14. Construction of facilities for destruction of PCB-containing equipment.

15. Reporting of spillage, housekeeping and maintenance frameworks need to be established within facilities to aid management protocols.

The above stated recommendations from the study require that sites will need to be managed in an environmentally sound manner. It also addresses the likelihood of site activities to generate significant adverse effects from construction works, upgrading of laboratories, and enhancement of interim storage facilities.

This underscores the need to develop An Environmental and Social Management Framework (ESMF) for the PCB Management Project in Nigeria. The choice of the ESMF is hinged on the fact that at this time of project preparation, the nature of impacts and the sites or facilities selected for the interim locations are not known to permit the preparation of an Environmental Impact Assessment (EIA) or an Environmental and Social Impact Assessment (ESIA)





1.1 InitiativeFollowing the outcomes of the PCB studies undertaken in the country with assistance from the Canadian Trust Fund on POPs and facilitated by the World Bank in 2008 and 2009, the government and the Bank felt it was necessary to prepare a GEF project addressing most of the recommendations in the two studies.

The proposed project is expected to positively impact both national and global objectives. At the global level, the project will assist Nigeria in meeting its obligations under the Stockholm convention and contribute to global efforts to control toxic chemicals and eliminate POPs in general and PCBs in particular.

On the national level, it will support the implementation of the NIP, National Strategy for Environmental Protection, and the vision 2020 with special attention to pollution, prevention, abatement, remediation and management theme.

1.2 World Bank EA requirements and complianceEnvironmental Assessment Policy OP/BP 4.01 is the umbrella policy within the 10 World Bank safeguards policies, and addresses mitigation, monitoring, institutional responsibility and training.

Most environmental assessment instruments like the present document of ESMF usually contain an Environmental Management Plan (EMP), which elucidates the following areas within the context of the proposed project:

Policy

1. Compliance with legal requirements and voluntary commitments.

2. Minimizing waste and preventing pollution.

3. Continual improvement in environmental, health and safety performance.

4. Sharing information on environmental performance.

Planning

1. How the activities of the PCB management project will affect the immediate community, national and global environments in terms of implementing the tasks of proposed project components.

2. Detailing the legal and institutional responsibilities associated with protecting the environment from the possible impacts of the PCB contaminated sites and the management project.

3. Setting meaningful and focused environmental objectives and targets to guarantee project implementation and sustainability.



Implementation and Operation

1. Definition of tasks to meet environmental objectives and targets.

2. Tasks identification and assignment of responsibilities.

3. Set task completion and targets.

Project EMP Management & Evaluation

1. Routine monitoring, evaluation and continual improvements to ensure optimal implementation of set project environmental, safety and health targets.

1.3 Key IssuesThe PCB studies undertaken in 2008 and 2009 threw up challenges for the environmentally sound management of PCBs in Nigeria, and issues to bring the country into full compliance with its obligations to the Stockholm Convention.

The key issues opened up by the studies were:

The need for a comprehensive and detailed PCBs Inventory covering all PCBs users in all the states and the FCT.

The confirmation of all chlorination positive fields screening test results with laboratory analysis in an environmental laboratory experienced and equipped for organo-chlorines analysis.

Development of mechanisms for the final elimination of PCBs in the country by 2025. Improvement of awareness and training among PCBs users and the general public. Development of a legal, regulatory and policy framework for the management of

PCBs in the country with the identification of institutional responsibilities.

Development of Environmental, health and safety practices for on-line and off-line equipment, wastes and oil in PHCN facilities.

Labelling and development of environmentally sound temporary storage facilities for potentially PCBs contaminated wastes, equipment and oil in PHCN facilities.

Long-term monitoring and evaluation of potentially PCBs-contaminated sites should be conducted to determine management approach, evaluate the effectiveness of the chosen management option, and ensure adequate, continuous protection of humans and the environment



1.4 PCB Management in NigeriaPolychlorinated biphenyls (PCBs) are a class of synthetic organic chemicals that are, to a large extent, chemically inert. PCBs have been widely used as additives to oils in electrical equipment, hydraulic machinery, and other applications where chemical stability has been required for safety, operation, or durability. Although the chemical stability of PCBs is useful technologically, their persistence, ability to travel long distances, and toxicity make them dangerous environmental health pollutants. The protection of human health and the environment requires that PCBs be disposed of in an environmentally sound manner.

Since all electricity business in Nigeria (generation, transmission and distribution) is for now, run by the Power Holding Company of Nigeria (PHCN), it follows that almost all PCB related activities are centered in and around PHCN.

In 2001, the government of Nigeria received funding from the Global Environment Facility (GEF) to finance enabling activities that would lead to the preparation of its NIP on the Stockholm Convention. Federal Ministry of Environment was the Implementing Agency and UNIDO the executing agency for the project. Given the size of the country, its level of economic development and its complex government structure, and taking into account the amount of GEF resources available, the level of detail that could have been expected from these inventories was limited.

In spite of the inadequacy of the existing PCB survey conducted under the GEF project, the government of Nigeria through the Federal Ministry of Environment, Housing and Urban Development has highlighted PCB management as one of its top priorities regarding POPs. This is due to several reasons:

1) The Nigerian electricity sector has facilities located in all 36 states and the Federal Capital Territory, with about 250 transmission transformers, 34,800 distribution transformers, and over 2,000 power transformers. Although this equipment was not surveyed by the inventory, PHCN has informed the Ministry of Environment that equipment is of various ages and states of repair. According to some of the observations included in the inventory report, it is likely that many of these transformers contain PCBs and that a significant number of them may not be providing adequate containment for the oils. The Ministry of Environment is therefore very concerned about the potential harm these equipments might be posing to the health of people living and working nearby PHCN facilities, as well as to the environment.

2) The government of Nigeria, and more specifically the Ministry of Power, is undergoing a massive upgrade of its electricity generation and distribution capacities. As one of the government’s top development priorities, it plans an up to 10,000 MW increase of its installed electricity generation capacity. Some of the upgrades will involve replacement of old equipment, which may be contaminated with PCBs. It is therefore critical for the government to have a clearer picture of contamination of PHCN’s electrical equipment with PCB, such that plans to adequately manage the decommissioning of this equipment in an environmentally sound manner can be put in place.



3) The risks to human health and to the environment posed by the unsound management of privately owned PCB-containing equipment or PCB stocks are also a priority of the government. In particular, information about illegal trade of spent oils, poorly managed and inadequately disposed equipment is a source of grave concern, although no actual data currently exists to assess the situation. Compiling data about these issues will allow to for better planning of the level of government enforcement of private sector operations that will be required to safe-guard human health and environmental safety.

1.5 Policy, Legislation and GuidelinesEnvironmental policy, sustainable development policy and general legislative framework

Environmental management in Nigeria is hinged on the 1989 National Policy on the Environment as revised in 1998, as well as a set of laws, regulations and guidelines to ensure the conservation of natural resources and the protection of the environment and human health. The goal of the National Policy on the Environment Government of Nigeria is to achieve sustainable development in Nigeria, and in particular to:

Secure for all Nigerians a quality of environment adequate for their health and wellbeing;

Restore, maintain and enhance the ecosystems and ecological processes essential for the functioning of the biosphere to preserve biological diversity and the principle of optimum sustainable yield in the use of these natural resources and ecosystems;

Raise public awareness and promote understanding of essential linkages between environmental and development and to encourage individual and community participation in environmental improvement efforts; and

Cooperate in good faith with other countries, international organizations/agencies to achieve optimal use of transboundary natural resources and effective prevention of transboundary environmental pollution.

Before and after independence in 1960, most of the legislations that can be called environmental laws in Nigeria were resource-specific or sector specific and were also piecemeal and not coordinated. Further to the discovery of about 4,000 tonnes of toxic wastes illegally dumped in Koko port in the old Bendel state (Koko port is now in Delta State) in 1988, the Federal Government promulgated on 30 December 1988 Decree No. 58 of 1988 establishing the Federal Environmental Protection Agency (FEPA) (as amended by Decree No. 59 of 1992) as the apex organisation for all matters relating to environmental protection and natural resources conservation in the country. The decree is now incorporated as an Act in Chapter 131 Laws of the Federation of Nigeria, 1990. The intention is that while the Federal Level controls all conservation and environmental protection issues, roles for participation in the implementation of the national policy on environment should be allocated to the states and local governments.



Consequently, State Environmental Protection Agencies (SEPAs) were established in the states while Environmental Committees were also established at the local government levels. The National Council on Environment provides the platform for periodic federal–states consultations on environmental issues as well the harmonisation of implementation strategies for implementing environmental laws and regulations.

The Federal Environmental Protection Agency (FEPA) Act is the major framework law on environment in Nigeria as its provisions provide the framework for further legislations in specific aspects of environment. FEPA metamorphosed into the Federal Ministry of Environment in June 1999. All FEPA’s laws are still in force because they have not been repealed. Since a ministry is more of a policy-making organ, the Federal Government established in November 2006 the National Environmental Standards and Regulations Enforcement Agency (NESREA) with powers similar to the defunct FEPA for effective enforcement of environmental regulations in the country. The federal laws are the minimum standards in the states. The Constitution allows states to establish stricter standards than the Federal and also impose stiffer penalties on violators.

The defunct FEPA advocated the inclusion of environmental considerations in the planning and decision making process and in the execution of major developmental projects in Nigeria. This led eventually to the enactment of Decree No. 86 of 1992, which makes Environmental Impact Assessment (EIA) mandatory for all new major development projects such as industrial chemicals manufacturing, oil and gas development projects, infrastructure development projects (e.g., road, airport and seaport construction, etc.) The enactment of this law was a major and strategic follow-up action by FEPA to AGENDA 21 of the Rio Earth Summit held in Brazil in 1992.

Roles and responsibilities of ministries, agencies and other governmental institutions involved in POPs life cycles

In Nigeria, the national infrastructure for the management of chemicals is cross-sectoral in nature. As such there are a number of piecemeal legal instruments addressing various aspects of chemicals management. The four main organisations identified as major players in the management of chemicals in the country are the Federal Ministry of Environment; Federal Ministry of Health; National Agency for Food and Drug Administration and Control (NAFDAC) – an agency under the Federal Ministry of Health; and the Factory Inspectorate Division of the Federal Ministry of Labour and Productivity. The laws in place require that chemicals usage should be tracked through registration, and management from “cradle to grave”, that is from importation through formulation, usage, distribution through disposal based on the life cycle approach.



There is a policy framework, the National Policy on Environment, which approves policies for infrastructure and enforcement requirements, laws and guidelines for the management of potentially bio-accumulative and toxic substances such as POPs in Nigeria.

1.6 National Laws and RegulationsNational Environmental Protection, and Management of Solid and Hazardous Wastes Regulation (1991) (FMENV).

This provides that the objective of solid and hazardous waste management shall be to:

Identify solid, toxic and extremely hazardous wastes dangerous to public health and environment,

Provide for surveillance and monitoring of dangerous and extremely hazardous wastes and substances until they are detoxified and safely disposed,

Provide guidelines necessary to establish a system of proper record keeping, sampling and labelling of dangerous and extremely hazardous wastes,

Establish suitable and provide necessary requirements to facilitate the disposal of hazardous wastes;

Research into possible re-use and recycling of hazardous wastes.

Environmental Impact Assessment Act No. 86, 1992 (FMEnv)

This Act provides guidelines for activities of development projects for which EIA is mandatory in Nigeria. The Act also stipulates the minimum content of an EIA as well as a schedule of projects, which require mandatory EIAs. Table 1.1 shows existing legal instruments which addresses the management of chemicals in Nigeria

Forestry Law CAP 51, 1994

The Forestry Act 1958 which was amended as the Forestry Law CAP 51, (1994) prohibits any act that may lead to the destruction of or cause injury to any forest produce, forest growth or forestry property in Nigeria. The law prescribes the administrative framework for the management, utilization and protection of forestry resources in Nigeria, which is applicable to the Savannah, and other forest resources.

Land Use Act of 1978

The land-use Act of 1978 states that “… it is also in the public interest that the rights of all Nigerians to use and enjoy land in Nigeria in sufficient quality to enable them to provide for the sustenance of themselves and their families should be assured, protected and preserved”.

The Federal Ministry of Environment has specific powers to:

Develop plans of action and advise the Federal Government on national environmental policies and priorities;



Prescribe standards for and make regulations on air quality, water quality, pollution and effluent limitations, the atmosphere and ozone protection, control of toxic and hazardous substances including hazardous chemicals;

Monitor and enforce environmental protection measures; Enforce international laws, conventions, protocols and treaties on the environment; Promote cooperation with similar bodies in other countries and international agencies

connected with environmental protection; and Cooperate with Federal and State Ministries, Local Governments, statutory bodies

and research agencies on matters relating to the protection of the environment.

1.7 International Laws and RegulationsNigeria is signatory to several laws, treaties and regulations that govern the environment.

Among these are:

(i) World Bank Guidelines on Environmental Assessment {EA} (1991)(ii) International Union for Conservation of Nature and Natural Resources

(IUCN) Guidelines

(iii) Convention of Biological Diversity(iv) Convention Concerning the Protection of the World Cultural and National Heritage

Sites (World Heritage Convention)

World Bank Guidelines on Environmental Assessment {EA} (1991)The World Bank requires the preparation of Environmental Assessment document on proposed activities by a borrower as a pre-requisite for granting any financial assistance in form of loans; especially if the Bank safeguards policies are triggered and the projects are categorized into A or B. Potential issues to be considered for EA within the context of the proposed project include the following:

Biodiversity Cultural Properties Hazardous and Toxic Materials

Other international conventions relevant to the sound management of POPs and other hazardous chemicals to which Nigeria is party include;

The Rotterdam Convention on the Prior Informed Consent for certain hazardous chemicals and pesticides in international tradeThe Rotterdam Convention is a global agreement which seeks to promote shared responsibility and cooperative efforts among Parties in the international trade of certain hazardous chemicals in order to protect human health and the environment. It establishes a Prior Informed Consent (PIC) procedure, which seeks agreement from importing countries to accept shipments of certain hazardous chemicals. The POPs listed in the Stockholm Convention are all included in the Rotterdam Convention, which Nigeria ratified in 2004.



The Basel Convention on the Control of Trans-boundary Movements of Hazardous Wastes and their disposal (1989)The Basel Convention is a global agreement which addresses the problems and challenges posed by the trans-boundary movement and management of hazardous wastes, including those consisting of, containing or contaminated with POPs. It was adopted on 22 March 1989 and came into force on 5 May 1992. Nigeria became a party to the Convention in 1992.

The Basel Convention uses a Prior Informed Consent (PIC) procedure to control trans-boundary movements of waste, whereby hazardous waste cannot be shipped from one country to another without the consent of those countries involved, including countries of transit. The Convention has developed guidelines for managing wastes contaminated by chemicals in Annexes A and B of the Stockholm Convention and recognizes these guidelines as BATs and BEPs.

The Basel Convention was amended in 1995. The amendment prohibits the export of all hazardous waste from Parties that are members of the EU, OECD and Liechtenstein to all other Parties to the Convention. The ban is not yet in force in its own right.

ILO Convention on the Safety of Chemicals at the Workplace (1990)

Bamako Convention on the Control of Trans-boundary Movements of Hazardous Wastes (1991)This convention is the only regional convention on hazardous wastes. It was put together by the African Region with the inclusion of radioactive waste which is missing in the Basel Convention. Nigeria has ratified the convention.

FAO International Code of Conduct for the Distribution and Use of Pesticides (as amended in 2003)

The Strategic Approach to International Chemicals ManagementThe International Conference on Chemicals Management held in February 2006 finalised and adopted the Strategic Approach to International Chemicals Management. SAICM is a global framework to improve chemicals management. It is a voluntary agreement supported by a high-level declaration and contains a toolkit of policies and activities aimed at raising the standards of chemicals management, particularly in developing countries. SAICM will pull together international bodies with responsibility for chemicals management and will support and enhance the global treaties that cover chemicals and hazardous waste. Nigeria is actively involved in SAICM activities.

Nonetheless none of the aforementioned Multilateral Environmental Agreements MEAs has been domesticated as part of national environmental legislation.

Triggered World Bank Policies

The proposed PCB project triggered World Bank Operational Policy (OP)/Bank Procedure (BP) 4.01: Environmental Assessment.



The is the umbrella policy for the Bank's environmental 'safeguard policies' which among others include: Natural Habitats (OP 4.04), Forests (OP 4.36), Pest Management (OP 4.09), Physical Cultural Resources (OP 4.11), and Safety of Dams (OP 4.37)

The Bank requires environmental assessment (EA) of projects proposed for Bank financing to help ensure that they are environmentally sound and sustainable, and thus improve decision making.

Such EA are carried out by the borrower to evaluate the project's potential environmental risks and impacts in its area of influence. The EA process analyzes project alternatives; identifies ways of improving project selection, siting, planning, design, and implementation by preventing, minimizing, mitigating, or compensating for adverse environmental impacts and enhancing positive impacts; and includes the process of mitigating and managing adverse environmental impacts throughout project implementation. The Bank favors preventive measures over mitigatory or compensatory measures, whenever feasible. The Bank has categorized projects based on the type of EA required.

Category A - projects are those whose impacts are sensitive, diverse, unprecedented, felt beyond the immediate project environment and are potentially irreversible over the long term. Such projects require full EA.

Category B - projects involve site specific and immediate project environment interactions, do not significantly affect human populations, do not significantly alter natural systems and resources, do not consume much natural resources (e.g., ground water) and have adverse impacts that are not sensitive, diverse, unprecedented and are mostly reversible. Category B projects will require partial EA, and environmental and social action plans.

Category C - Projects are mostly benign and are likely to have minimal or no adverse environmental impacts. Beyond screening, no further EA action is required for a Category C project, although some may require environmental and social action plans.

Category FI - A proposed project is classified as Category FI if it involves investment of Bank funds through a financial intermediary, in subprojects that may result in adverse environmental impacts.

The World Bank Pollution Prevention and Abatement Handbook describes pollution prevention and abatement measures and emission levels that are normally acceptable to the Bank. However, taking into account borrower country legislation and local conditions, the Bank works with alternative emission levels and approaches to pollution prevention and


http://lnweb18.worldbank.org/ESSD/envext.nsf/51ByDocName/PollutionPreventionandAbatementHandbook


abatement for projects. The EA report must provide full and detailed justification for the levels and approaches chosen for the particular project or site.

Other World Bank Policies - Operational Policy/Bank Procedure 4.04 - Natural Habitat - seeks to ensure that

World Bank-supported infrastructure and other development projects take into account the conservation of biodiversity, as well as the numerous environmental services and products which natural habitats provide to human society

- Operational Policy/Bank Procedure 4.36 - Forests. This policy aims to reduce deforestation, enhance the environmental contribution of forested areas, promote afforestation, reduce poverty, and encourage economic development.

- Operational Policy 4.09 - Pest Management - policy recognizes that pesticides can be persistent and harmful to the environment for a long time. If pesticides must be used, the policy requires that Pest Management Plan (PMP) be prepared by the borrower, either as a stand-alone document or as part of an Environmental Assessment for

- Operational Policy /Bank Procedure 4.11 - Physical Cultural Resources seeks to avoid, or mitigate, adverse impacts on cultural resources from development projects that the World Bank finances.

- Operational Policy (OP) 4.37 - Safety on Dams requires that experienced and competent professionals design and supervise construction, and that the borrower adopts and implements dam safety measures through the project cycle. The policy also applies to existing dams where they influence the performance of a project. In this case, a dam safety assessment should be carried out and necessary additional dam safety measures implemented.

- Operational Policy 4.12: Involuntary Resettlement is concerned with situations involving involuntary taking of land and involuntary restrictions of access to legally designated parks and protected areas. The policy aims to avoid involuntary resettlement to the extent feasible, or to minimize and mitigate its adverse social and economic impacts.

It promotes participation of displaced people in resettlement planning and implementation, and its key economic objective is to assist displaced persons in their efforts to improve or at least restore their incomes and standards of living after displacement.

Other Bank policies that are not considered relevant to the PPP program are:

- Operational Policy (OP)/Bank Procedure (BP) 4.10 - Indigenous Peoples.



- Operational Policy (OP)/Bank Procedure (BP) 7.50 - Projects on International Waterways

- Operational Policy (OP)/Bank Procedure (BP) 7.60 - Projects in Disputed Areas




Table1.1: Existing Legal Instruments which Address the Management of Chemicals in Nigeria

Legal Instrument (type, reference year)

Responsible Ministries or bodies

Chemicals Use Category Covered

Objectives of Legislature Relevant Articles, Provisions Resources Allocated Enforcement Ranking

S.1.8 National Environment Protection (Effluent Limitation)Regs.1991

FEPA Chemicals and Chemical Waste

Environmental protection; effluent and waste water pollution control

Section 1-6 N/A 2

S.1.9 National Environment protection (pollution Abatement in ind. ssand facilities Generation wastes). Rags 1991

FEPA chemicals and chemical waste

Environmental protection, pollution Abatement; safety

Section 1-23 N/A 2

S.1.5 National Environment protection (management of solid and Hazardous Wastes).Regs.1991

FEPA Industrial and Consumer Chemicals radioactive substances agrochemical

Environmental protection, sound environmental management of solid and hazardous waste including storage trasnboundary movement, treatment and disposal

Part 1-12 N/A 2

FEPA Decree 58 of 1998 (Amended by FEPA Decree 59 of 1992)

FEPA Industrial agrochemical domestic

Environment protection, pollution abatement and control; human health est. FEPA Enforcement of FEP Regulation

Section 15,16,17,18,19,20 30 million 1

Decree 86 –Environmental Impact Assessment 1992

FEPA Industrial Environmental protection, human health (by evaluation/assessment of the suitability of locating a new industry at a site in the light of its environmental impact)

Section 13,sub section 8 N/A 1

Guidelines and standards FEPA All chemicals Environmental protection Part 1-1V N/A 2

Harmful Waste ( special Criminal Provision etc.)Decree 1988

FEPA Agrochemical; industrial and consumer chemicals toxic hazardous waste

Environmental protection; human health;

N/A 2


NAFDAC Decree 15 1993 NAFDAC Chemical Control of importation, exportation, manufacture, advertisement, distribution, sale. Of use of chemicals; health hazard prevention

Section 5 N/A 1

Factories Fed. Min. of labour and productivity

Industrial chemicals Occupational safety and health Section 2,3,11,1,30 ,45 N/A 2

Legal Instrument (type, reference year)

Responsible Ministries or bodies

Chemicals Use Category Covered

Objectives of Legislature Relevant Articles, Provisions Resources Allocated Enforcement Ranking

Pesticides Registration Regulation 1996

NAFDAC Pesticides Registration of Pesticides safety of pesticides

Section 1-9 N/A 1

Pharmacy council Decree 1992 Fed.Min.of Health pharmaceuticals Regulation, appointments and discipline

N/A 1

IPAN Decree No.100 of 1992 Fed.Min. of Health All chemicals Regulation/appointment and discipline of public analysts

N/A 2

Customs and Excise Act 1990 Fed.Min. of Finance All chemicals Regulation of all importation N/A 2

Standard organization of Nigeria Fed.Min. of industry Standards for quality of chemicals

Standarlizations of products including chemicals

N/A 2



Occupational Safety and health

Guidelines

Fed.Min. of Labour and Productivity Fed.Min. of health

Cement, textile industrial chemicals

Safety and health workers

N/A 2

Nig. Port Authority Act Fed.Min. of transport All chemicals Transporting of chemical goods Part 11 section 3,subsection 2 N/A 2

Nig.Maritime Decree Fed.Min. of Transport All chemical Transporting of chemical goods N/A 2

DPR Guidelines and standards DPR Drilling chemicals and explosives and chemical additives

Regulates the petroleum N/A 2

NDLEA Decree Fed.Min. of Justices Narcotics and psychotropic’s

Regulation and Monitory N/A 2

*) Enforcement ranking :1-Effective 2- Fair 3-Week

Adapted from: Federal Republic of Nigeria-National Implementation plan for the Stockholm Convention on persistent organic pollutant



CHAPTER 2 : PROJECT DESCRIPTION

2.1 Project country-Nigeria Overview

COUNTRY PROFILE FEDERAL REPUBLIC OF NIGERIA

Capital Abuja

Area 923,768 km2

Land boundaries 4,047 km (Benin 652 km, Cameroon 773 km, Chad 87 km, Niger 1,497 km)

Coastline 853 km

Climate Equatorial in the south, tropical in the centre, arid in the north

Terrain Southern lowlands merge into central hills and plateaus; mountains in north-east, plains in north

Elevation Lowest point: Atlantic Ocean 0 m, highest point: Chappal Waddi 2,419 m

Land use Arable land: 33.02%, permanent crops: 3.14%; other: 63.84% (2005)

Irrigated land 2,820 km2 (2003)

Natural hazards Periodic droughts; flooding

Environmental issues Soil degradation (Erosion, especially in the Eastern parts of the country); rapid deforestation; urban air and water pollution; desertification; oil pollution - water, air, and soil; has suffered serious damage from oil spills; loss of arable land; rapid urbanization

Geography note The Niger River enters the country in the northwest and flows southward through tropical rain forests and swamps to its delta in the Gulf of Guinea

Population 131,859,731 (July 2006 est.)

Age structure 0-14 years: 42.3%; 15-64 years: 54.6%; 65 years and over: 3.1% (2006 est.)

Growth rate 2.38% (2006 est.)



Life expectancy Total population: 49 years - female: 48 years - male: (2006 estm.)

Total fertility 5.49 children born/woman (2006 est.)

Ethnic groups More than 250 ethnic groups; Major groups are, Hausa/Fulani , Yoruba, Igbo, Ijaw, Kanuri, Ibibio, Tiv.

Religions Christianity, Islam, Traditional religion

Languages English (official), Hausa, Yoruba, Igbo

Independence 1st October, 1960

Economy GDP (2007): $166 billion (agriculture 33%; industry 39%; services 28%).Real GDP growth rate (2007): 5.9%. Oil growth: -5.6%. Non-oil growth: 9.6%.Per capita GDP (2007): $1,149. Inflation (2008): 8.5%. Natural resources: Oil and natural gas (37% of 2006 GDP), tin, columbite, iron ore, coal, limestone, lead, zinc. Agriculture: Products--cocoa, palm oil, yams, cassava, sorghum, millet, corn, rice, livestock, groundnuts, cotton. Industry: Types--textiles, cement, food products, footwear, metal products, lumber, beer, detergents, car assembly. Trade (2007): Exports--$65.5 billion: fuels and mining products (97%); agricultural products (cocoa, rubber, oil, nuts) (2.2%); manufactures (0.8%).. Currency: Naira (152 Naira = U.S. $1 as of Nov. 13, 2009).



2.2 Project Scope

The Project scope covers the whole 36 states and the Federal Capital Territory (FCT)

2.3 Project ObjectivesThe project development objective (PDO) is to develop national capacity to manage PCBs, and develop and enhance in-country storage facilities for PCBs until their environmentally sound disposal can be achieved. The key indicators of this project are to:

a) Strengthen the institutional and legal framework for PCBs management in Nigeria.

b) Ensure that inventoried PCBs and PCB-containing equipment are labelled, safely transported and stored; reducing risks of exposure to PCBs on human health and the environment.

c) Identification, adoption and implementation Best Available Technology (BAT) and Best Environmental Practices (BEP) in addressing PCBs management in the country, especially in PHCN facilities.

2.4 Description of the Proposed PCBs Management Project

2.4.1 Project ComponentsThere are 4 main components of the project:

e) Component 1: Capacity Building for PCB Management;

f) Component 2: Design, development and implementation of environmentally sound management (ESM) for online and offline electrical equipment and potentially contaminated sites;

g) Component 3: Baseline national inventory of PCBs and PCB containing equipment, and development of a national PCB management plan;

h) Component 4: Project management and Monitoring and evaluation.

Component 1: Capacity Building for PCB Management (2,106,078 USD: GEF: 1,179,754 USD, Government, 926,324 USD): This component aims to strengthen the government’s capacity to manage, monitor, control and ultimately phase out the use of PCBs. Activities under this component will include a comprehensive review of current hazardous waste management regulations, and the development and incorporation of a new regulatory framework that will specifically address PCBs. The component will also contain a communication strategy and address the issue of training and awareness



(including stakeholders workshop), and will involve the preparation and dissemination of training materials including TV programmes/documentaries, posters and the production of brochures/pamphlets for the purpose of raising awareness on PCB issues.

Component 2: Design, development and implementation of environmentally Sound Management (ESM) for on-line and off-line electrical equipment and potentially contaminated sites (9,419,396 USD: GEF 3,273,208 USD, Government 6,146,188 USD): This component will involve series of investment activities that will provide the government with the enabling capacity to handle PCBs in the future. This will consist of:

a) Development of detailed procedures, manuals, management protocols and guidelines for the identification and management of PCBs, PCB-containing or PCB-contaminated equipment and wastes. The sub-component will also entail labelling of all identified PCB containing electrical equipment and wastes so as to ensure good maintenance practices;

b) Identification and upgrading of laboratories for analyzing PCBs in oils, water and soil samples – Activities under this component will assess the capacities of the existing laboratories in analyzing PCBs, and determine with a view to selecting appropriate in-country analytical techniques. This component will also upgrade equipment and testing procedures, and help establish facilities in-country that will be utilized for definitive identification of PCBs including improvement of existing personnel capacities.

c) Identification and possible enhancement of interim storage locations - This will involve identification and enhancement of storage locations that will safely handle PCB wastes and PCB-containing equipment to prevent the release of such wastes into the environment. These facilities will be used to store decommissioned PCB-containing equipment and PCB wastes in an environmentally sound manner. As treatment and final disposal of PCB containing materials are not considered as part of this project, existing locations like the Ijora workshop in Lagos and sub-stations at Kontagora, Kaduna, and Oji River will be assessed for their suitability as interim storage locations. Such interim storage facilities will be used until effective treatment and disposal capacity is made available in the long term.

d) Development of strategies for PCB management and containment at the national level – This component aims to evolve strategies for PCB management and containment, including pilot demonstration in selected sites. The Pilot demonstration will cover activities such as identification of PCB–contaminated oils, equipment and wastes, conducting of oil sampling and analyzing the samples to determine level of PCB contamination and management practices. The achievements of the field implementation measures at the demonstration pilots will be available for replication and implementation in other areas of the country.

e) Development of guidelines for characterization and risk assessment of contaminated sites – This component will complement the ongoing UNIDO project between Nigeria and Ghana on management of POPs contaminated sites.



Activities under this component would consists of preparing contaminated site characterization and risk assessment guidelines which will enable the government to prioritize sites according to their potential impact on human health and the environment. This will enable the government to select economically feasible and environmentally sound risk management options.

Component 3: Baseline national inventory of PCBs and PCB -containing equipment and development of a national PCB management plan (4,871,148 USD: GEF 1,373,197 USD, Government 3,497,951 USD): This component will be built on the recently conducted partial PCB inventory that covered 10 states out of the 36 states and the Federal Capital Territory. Activities under this component will include the establishment of a data base for PCB containing equipment and wastes in 15 additional states and the development of comprehensive methodology for conducting inventories. The government will apply this methodology to cover the remaining 11 states and the Federal Capital territory in the future. This will include sampling and testing of potentially contaminated equipment owned by the private sector and government. The outcome of this inventory will provide a clear picture on the extent of PCB contamination across the country. Based on the outcome of this inventory, a long term PCB management plan will be developed.

Component 4: Project Management and Monitoring and Evaluation – (2,103,377 USD: GEF 473,841 USD, Government, 1,629,536 USD): This component will finance costs related to the establishment of the Project Management Unit (PMU) and incremental operational costs of the PMU. This component will also ensure the proper coordination and timely delivery of project outputs. The PMU will carry out the usual project management functions of financial management, procurement, auditing, managing, monitoring and evaluating project implementation, and dissemination of project results. The M&E tools to be developed under this project are expected to be institutionalized for the management of all PCBs in Nigeria. The PMU will include a Project Coordinator, an accountant, a procurement specialist, an Environment Specialist and an M&E/Data Management Specialist.



CHAPTER 3: APPROACH TO ENVIRONMENTAL AND SOCIAL ASSESSMENT This chapter describes the technique used to assess environmental and social impact for the entire project (including “Location and Assessment” and that to be used for assessing the impact of the component activities).

The document is a consequence of data acquisition from general research done by the consultant, results of task team deliberations, consultations with the donor (the World Bank), the borrower (Federal Republic of Nigeria/Ministry of Environment), and discussions with other stakeholders (inclusive of PHCN facilities managers, PHCN management staff, and PHCN general ground staff).

3.1 Environment and Social Safeguard PoliciesFor the project, the World Bank Environmental Assessment policy (OP 4.01) was triggered. The EA considers the natural environment (air, water and land); human health and safety; and lastly, social aspects.

The project is considered Category B, since the potential negative impacts are likely to be site specific. This EA is destined to address the up-grading of laboratories and the enhancement of interim storage locations.

3.2 Typical information provided in the EA documentFor this ESMF, the information provided includes:

I. The Project descriptionII. A description of the baseline environment

III. An analysis of alternatives to the projectIV. An assessment of likely impacts resulting from the projectV. A description of measures to mitigate the unavoidable impacts

VI. An EMP which would generally highlight the impacts and mitigation measures proposed, and set out a monitoring plan with clear assignment of roles and responsibilities.

3.3 Activities Covered under the ESMFThe Environmental assessment focused on the activities that required physical disturbance and those that required handling of the hazardous material/equipment. These activities either directly alter the site, or have the capacity to cause pollution. Other activities which are non-physical involve: Capacity building, development of strategies and guidelines, inventorization, monitoring and evaluation.



Ijora Power Station, Lagos – Disused potentially PCBs containing equipment stored in a pond filled with waste transformer oil



3.4 ESA Instruments required for each Component Table 3.1: EA instrument and WB category

Component Activity WB Project Category WB EA Instrument

Component 1

(i) Comprehensive review of current hazardous waste management regulations

(ii) Development and incorporation of a new regulatory framework that specifically addresses PCBs

(iii)Training and awareness

Category C EMP

Component 2a

(i) Development of procedures and guidelines for identification of all waste and equipment consisting/contaminated with PCBs

(ii) Labelling of all identified PCBs containing equipment and waste

Category C EMP

Component 2b

(i) Assessing capacities of existing labs in analyzing PCBs

(ii) Upgrade of equipment and testing procedures

(iii) Establish in-country facilities for the definitive identification of PCBs

Category B Draft EA

Component 2c

(i) Identification and enhancement of suitable locations for PCBs waste storage

Category B Draft EA

(i) Developing monitoring guidelines for waste oil management



Component 2d Category C EMP

Component 2e

(i) Pilot demonstration for the identification of PCB-contaminated oils and equipment

(ii) Provision of pilot demonstration retention tanks for on-line transformers Category B Draft EA

Component 2f (i) Preparation of a contaminated site characterization and risk assessment guidelines

Category C EMP

Component Activity WB Project Category WB EA Instrument

Component 3

(i) Establish a database for PCBs containing equipment and waste

(ii) Development of a comprehensive methodology for conducting inventories

Category C EMP

Component 4 (i) Monitoring project progress

(ii) Finance costs related to establishing a PMU

(iii) Ensuring proper coordination and timely delivery of projects

Category C EMP




CHAPTER 4: POTENTIAL ENVIRONMENTAL IMPACTS OF EACH COMPONENT

4.1 Capacity Building for PCB ManagementActivities under this component will include a comprehensive review of current hazardous waste management regulations, and the development and incorporation of a new regulatory framework that will specifically address PCBs. The component will also address the issue of training and awareness (including stakeholders workshop), and will involve the preparation and dissemination of training materials including TV programmes/documentaries, posters and the production of brochures/pamphlets for the purpose of raising awareness on PCB issues.

This component will promote public awareness, participation and improved coordination in the execution of the activities of the PCBs management project. The main challenge with this component is the low key awareness amongst PHCN personnel including top management, and other key stakeholders (sellers and repairers of transformers, and the general public)

Constraints to the full achievement of this component will include:

Communication and overcoming language barriers preparedness Collaboration with stakeholders and simplification of technicalities for non-

technical stakeholders Development of modules for trainings (especially for PHCN personnel) and

provision of adequate training tools (audio-visuals, Posters, brochures, manuals Availability of requisite amount of financial resources for the execution of the

component

Generally, this component on its own is not expected to pose any negative/adverse impacts on the environment and health of the people. Its impacts are expected to be positive.

4.2 Design, development and implementation of environmentally sound management (ESM) for online and offline electrical equipment and potentially contaminated sites

f) Development of procedures, manuals, management protocols and guidelines for the identification of all equipment and wastes consisting of/contaminated with PCBs. The sub-component will also entail labelling of all identified PCB containing electrical equipment and wastes so as to ensure good maintenance practices;

Most of the activities of this sub-component will have no negative impacts. The negative health and environmental impacts from this sub-component are expected to be associated with activities to do with labelling and will include:


- Collapse of stacked equipment- Contact dermatitis and inhalation - Attack by vermin (snake bites, scorpion, rodents, spiders & insects)

Constraints to the successful implementation of this sub-component will include:

- Manpower inadequacy- Availability of requisite amount of financial resources for the execution of the

component- Logistics inadequacies

Stakeholder resistance

g) Identification and upgrading of laboratories for analyzing PCBs in oil, water and soil samples – Activities under this component will assess the capacities of the existing laboratories in analyzing PCBs, and determine with a view to selecting appropriate in-country analytical techniques. This component will also upgrade equipment and testing procedures, and help establish facilities in-country that will be utilized for definitive identification of PCBs including improvement of existing personnel capacities.

Most of the activities of this sub-component will have no negative impacts.The health and environmental impacts in this sub-component will emanate mostly from

- The construction and refurbishment of the physical structures e.g. drainage and sewage

- The transport of heavy mechanical equipments and reagents - The activities of the laboratory personnel during handling of possible

PCBs contaminated samples and materials. (Personnel should adhere to International Best Practices in Safety of Research Laboratories)

These impacts include:

(i) Dust production(ii) Short and temporary noise (iii) Increase in solid waste from construction works(iv) Laboratory operation posing health and safety risks to lab personnel(v) Damage of ecology and natural resource resulting from poor handling of

possible PCBs containing samples and materials.(vi) Extensive use of solvents which may pose fire hazards

The degree of significance will range from moderate to high.




- High cost of procurement and maintenance of high tech equipment for PCBs analysis

- Trans-boundary movement of procured equipment, and delay in clearance with local Customs and Excise authorities.

- Freight logistics inadequacies- Inadequate costs development for construction works and refurbishments;

inconsistent facility location, site planning and incoherence with structure specification.

h) Identification and possible enhancement of interim storage locations - This will involve identification and enhancement of storage locations that will safely handle PCB wastes/oils and PCB containing equipment to prevent the release of such wastes into the environment. As treatment and final disposal of PCB containing materials are not considered as part of this project, existing locations like the Ijora workshop in Lagos and sub-stations at Alagbon, Ikeja, Kaduna, and Oji River will be assessed for their suitability as interim storage locations. Such interim storage facilities will be used until effective treatment and disposal capacity is made available in the long term.

The health and environmental impacts in this sub-component will most likely arise from:

- Earthworks and Construction- Failure to adhere to specifications that meet international standards for

construction of storage facilities for PCBs containment; lack of provision of hard standing or concrete floors could permit the seepage of leaking oil into the ground and further into ground water.

- Transport and sorting of PCBs waste and PCBs containing equipment from designated facilities to interim storage locations.

The contractors or firms engage in the civil works associated with the up-grading of the laboratories and the enhancement of interim storage locations will need to abide to environmental and social management clauses for constructions (see annex 1)

i) Waste oil management and transformer maintenance guideline - Current and past electrical equipment maintenance practices in Nigeria have not been regulated and these consequently have led to the cross contamination of PCB in transformers. Recent inventory indicates that large number of electrical equipment, regardless of their manufacture date, have been found to be contaminated with PCBs. Activities under this sub-component will focus on developing monitoring guidelines for waste oil management and maintenance of electrical equipments that will prevent further cross-contamination.





(i) Lack of understanding of the guidelines proffered for executing proper waste oil management and maintenance of electrical equipments.

(ii) Lack of stakeholder co-operation and participation(iii) Inefficient legal and regulatory frameworks to encourage development,

participation and implementation of the activities of the sub-component.

j) Development of strategies for PCB management and containment at the national level – This component aims to evolve strategies for PCB management and containment, including pilot demonstration in selected sites. The Pilot demonstration will cover activities such as identification of PCB–contaminated oil, equipment and wastes, conducting of oil sampling and analyzing the samples to determine level of PCB contamination and management practices. It will also include the provision of pilot demonstration retention tanks for some selected on-line PHCN transformers for the collection of spilled dielectric fluids in case of accidents.



(i) The rigid organisational structure of PHCN as an organisation, as it may not provide the much-needed flexibility to divert their human resources to work on the project.

(ii) Additional time required to make the stakeholders understand and appreciate the approach

k) Development of guidelines for characterization and risk assessment of contaminated sites – This component will complement the ongoing UNIDO project between Nigeria and Ghana on management of POPs contaminated sites. Activities under this component would consists of preparing contaminated site characterization and risk assessment guidelines which will enable the government to prioritize sites according to their potential impact on human health and the environment. This will enable the government to select economically feasible and environmentally sound risk management options.

Generally, this component on its own is not expected to pose any negative/adverse environment and health impact. Its impacts are expected to be positive.


Communication and overcoming language barriers preparedness Collaboration with stakeholders and simplification of technicalities for non-

technical stakeholders Availability of requisite amount of financial resources for the execution of the



component

4.3 Baseline national inventory of PCBs and PCB containing equipment, and development of a national PCB management planActivities under this component will include the establishment of a data base for PCB containing equipment and wastes in 15 additional states and the development of comprehensive methodology for conducting inventories. The government will apply this methodology to cover the remaining 11 states and the Federal Capital territory in the future. This will include sampling and testing of potentially contaminated equipment owned by the private sector and government. The outcome of this inventory will provide a clear picture on the extent of PCB contamination across the country. Based on the outcome of this inventory, a long term PCB management plan will be developed. The management plan that is envisioned will consist of a cost effective schedule to phase out all potentially contaminated online electrical equipment, in a manner that is consistent with goals stipulated in the Stockholm Convention. The management plan will also include an assessment of disposal options for offline electrical equipment and PCB waste oils. Safeguarding, storage and disposal options for equipment and contaminated oils that are currently stored in different sites as well as those which will be taken offline by 2025 will be identified. A long term plan, which will include options for financing the cost of disposal, will be developed jointly with PHCN.

This component on its own is not expected to pose any negative/adverse environmental and health impacts. Its impacts are expected to be positive.

The positive impacts of this component will include:

1. The establishment of a platform for development of a concise database incorporating garnered information on the locations, types and quantities of PCBs contaminated equipment.

2. Provision for a foundation for the development of other sub-projects on PCBs management in Nigeria.

3. Provision of a platform for the development of legal and regulatory frameworks targeted towards successful PCBs management.


1. Non-provision of a soundly developed methodology to conduct concise and adequate inventory of potentially PCBs contaminated equipment.

2. Logistics inadequacies3. Stakeholder co-operation4. Inadequacies in technical requirements for task teams to conduct on-site

inventories of potentially PCBs contaminated equipment.

4.4 Project Management and Monitoring and EvaluationActivities under this sub-component include monitoring progress of project and



evaluating effectiveness of project implementation. The M&E tools to be developed under this project are expected to be institutionalized for the management of all PCBs in Nigeria.


The positive impacts of this component will include:

1. The enhancement of shared learning as regards the management of PCBs in the country

2. The increased capacity to measure progress with respect to the project3. The development of effective decision making and aiding further planning4. An increase in efficiency and effectiveness with respect to the project


1. Improper reporting2. Manipulation of data and indicators 3. Difficulty in identifying the most appropriate M&E tool to be used

Finance costs related to the establishment of the Project Management Unit (PMU) and incremental operational costs of the PMU. This component will also ensure the proper coordination and timely delivery of project outputs.


CHAPTER 5:PROJECT-RELATED MITIGATION STRATEGY

In this chapter, the recommended mitigation measures and strategies by component, and social safeguards in-view are discussed. The impacts and risks presented in chapter 4 have been considered in this chapter thereby providing a basis for development of these proffered measures.



5.1 Component 1: Capacity Building for PCBs Management

The activities of this component will promote public awareness, participation and improved coordination therefore eliciting no negative impact on health and environment.

This component thus will not employ any mitigation measures, but will focus seriously on the constraints which could impede successful implementation of the component activities.

5.2 Component 2: Design, Development and Implementation of Environmentally Sound Management (ESM) for Online and Offline Electrical Equipment and Potentially Contaminated SitesThe summary of sub-component activities of component 2, suggests the development and implementation of mitigation measures which address the risks in management of potentially PCBs contaminated equipment, materials and sites.

Mitigation will therefore employ the development of, or upgrading of PCBs Management Plans or guidelines. These measures will revolve around Policy making, monitoring, occupational safety and health, and institutional responsibilities.

Thus the general mitigation measure will be the preparation and acceptance of a “Technical Guideline for Environmentally Sound PCBs Management” which should be made available to all stakeholders from the public and private sectors.

5.2.1 Abstract of Mitigation measures by sub-component

Sub-component (a): Development of procedures, manuals, management protocols and guidelines for the identification of all equipment and wastes consisting of/contaminated with PCBs.

No negative impacts are expected from this sub-component.

Sub-component (b): The under-listed mitigation/management strategies will apply for the identification and upgrading of laboratories for analyzing POPs and in particular PCBs in oil, water and soil samples.

Check collapse prone areas by undertaking confirmatory tests on stability of compacted sites to prevent slides, and advance notification of nearby settlers of the work about to be done.

Provision of hydrants or sprinklers for water application on construction and excavation sites in order to reduce dust production and emissions during earthworks.

Use of PPEs, especially face masks to prevent bronchial congestion and asphyxiation.

Use of ear mufflers by construction workers to reduce negative impacts of noise production and pollution.



Waste minimization through reduction at source. Preparation of waste segregation procedures for all sample types aid

systematic handling. Provision of waste storage receptacles (laboratory interior and exterior)

with adequate cover to prevent the escape of volatile substances. Use of in and on-facility waste treatment technology in order to avoid

destruction of local fauna and flora. Implementation of occupational safety and health protocol, and benefit

packages. Duty compliance with international best practices in safety for research

laboratories. Investments in BAT/BEP

Sub-component (c): Identification and possible enhancement of interim storage locations:

The mitigation measures for this sub-component will address the resulting impacts of the envisaged activities. These measures include;

Construction and Earth works:

Design and operate effective surface water control measures Construction of concrete floors in the interim storage facilities to

prevent seepage of leaking oils into the soil and ground water. Establishment of a tracking system for vehicles that move in and

out of the storage remises; mud on tyres should be washed off and ground personnel kitted with full PPEs.

Isolate treated and contaminated areas and ensure that they are not re-contaminated by site works.

Check collapse prone areas and by undertaking confirmatory tests on stability of compacted sites to prevent slides, and advance notification of nearby settlers of the work about to be done.

Protection and sustenance of Surface water quality:

Install temporary barriers (e.g. geo-fabric) Excavate drainage or run-off water diversion trenches,

collection or absorption pits, ponds to capture and treat the run-off (e.g. remove sediment)

Protection and sustenance of Groundwater quality:

Construction of concrete floors in the interim storage facilities to prevent seepage of leaking oils into the soil and ground water.

Construction of leachate ponds and tanks and development of remediation solutions/strategies for ground water pollution.



Dust production:

Provision of hydrants or sprinklers for water application on construction and excavation sites in order to reduce dust production and emissions during earthworks.

Construct fences which will serve as wind barriers. Application of vegetative cover- native or introduced species. Maintenance of good housekeeping protocol.

Flora and Fauna:

Transplantation of vital economically important and beneficial flora.

Transport:

Preparation and implementation of emergency procedures as part of the guidelines to cover transport of potentially PCBs containing equipment and wastes to interim storage facilities.

Occupational health and safety: Provision of legal and regulatory frameworks on occupational

health and safety in PCBs management. Provision of adequate facilities for the welfare of on-site

personnel and employees. Development of a sit-specific safety Management plan which

presents all possible hazards, mitigation and responsible persons.

5.2.2 Development of Site- Specific Safety Management Plans for Interim Storage Sites/Locations

A Site-specific Safety Management Plan identifies the hazards associated with the particular work being undertaken on a site, along with the hazard and risk control measures that will be implemented to adequately protect people on the work site from the risk of injury or illness. The plan is a basic requirement, must be implemented, maintained and updated.

An ideal Site –Specific Safety Management Plan should address the following components:



1. Risk management – identification of the hazards and assessment of the risks associated with the work, and documentation of the risk control measures to be taken.

2. Statement of responsibilities – a statement that nominates individuals who will be responsible for the site-specific OHS aspects of the work, and who will be available to deal with illness/injury and OHS incidents.

3. Occupational health and safety training – a statement identifying the training needs of personnel on the work site, including OHS induction training for the work, and arrangements to address those needs.

4. Incident Management/Job Hazard Analysis – a statement identifying the processes to be used and personnel available to prevent, prepare for, respond to and recover from illness/injury and incidents.

5. Site Safety Rules – safety rules that should be displayed in prominent areas on the work site.

6. Safe Work Method Statements – statements for all work activities identified as having health or safety risks, identifying the measures to be used to manage those risks. Particular attention should be paid to work activities with a high safety risk (for example haulage of heavy electrical equipment such as transformers and reactors, working at heights, with or near hazardous substances-PCBs and other POPs, in tunnels or confined spaces, with cranes, with compressed air, with lasers, or in deep excavations). Checklist compliance is an integral part of this component.

Sub-component (d): Waste oil management and transformer maintenance guideline -In the preceding chapter on impacts posed by this sub-component, no negative impacts were identified.

Therefore, the activities of this sub-component will not require any mitigation measures.

Sub-component (e): Development of strategies for PCB management and containment at the national level.

The activities of this sub-component will not require any mitigation measures.

Sub-component (f): Development of guidelines for characterization and risk assessment of contaminated sites.The activities of this sub-component will not require any mitigation measures.



5.3 Component 3: Baseline national inventory of PCBs and PCB containing equipment, and development of a national PCB management plan.The activities of this component will not require any mitigation measures.

5.4 Component 4: Project Management and Monitoring and evaluationThe activities of this component will not require any mitigation measures.

CHAPTER 6:PCBs MANAGEMENT PROJECT – ENVIRONMENTAL ASSESSMENT

The World Bank environmental safeguard for Environmental Assessment (EA) – OP 4.01 aims to help ensure that proposed projects for WB financing are environmentally sound and sustainable, and help improve decision making. The Choice of an Environmental and Social Framework (ESMF) is hinged on the fact that intervention locations are not yet known as this time of project preparation. It is expected that site specific EMPs or EIA will be prepared especially on those sites selected for enhancement as interim storage locations. A typical ToR for an EIA is attached as Annex 2



A full EIA or EMP will consists of the following outline: Basic Information Project Description Baseline Environment Project Alternatives Impact Assessment Mitigation- EMP Monitoring- EMP Implementation Schedule-EMP Roles and Responsibilities-EMP Training Cost of Mitigation and Monitoring

6.1 Project Alternatives Consideration of alternatives should be in line with the overall project objective. Dumping of PCBs contaminated transformers, capacitors, disused oils and wastes have become a common practice in many PHCN facilities around the country. For example, the Ijora Power Station and Central Stores Kaduna are presently used as transformer storage and repair yards for the Power Holding Company of Nigeria (PHCN). Given the huge amount of potentially PCBs contaminated equipment, oil and wastes that have to be managed in an environmentally sound manner around the country until capacity for their final disposal is available, several alternatives for management of the stockpiles have been assessed.

Factors considered in the alternatives definition include:

1. Immediate disposal of potentially PCBs contaminated wastes on-site in their various present locations utilizing mobile incineration.

2. Import of major advanced technology option (incineration, plasma arc, de-chlorination, solvent washing, autoclaving) for the management/disposal of the PCBs stockpile in-country at a centralized location.

3. On-site use of alternative BAT/BEP low cost technology option (such as biotechnology) for decontamination of the sites.

4. Export of the potentially PCBs contaminated equipment to another country with technological capacity for the management/disposal of PCBs.



5. Long term storage of the potentially contaminated equipment and wastes in centralized interim storage locations around the country until Nigeria is able to develop in-country capacity for the management of its PCBs wastes stockpile.



S/No. Alternative Type Advantages Disadvantages Remarks

1. Do nothing option Inexpensive - Environmental degradation

- Bioaccumulation in food chain with severe health consequences

2. Immediate disposal using In-country disposal or decontamination technology ( e.g. mobile incineration)

-Quick solution

-Effective if Incinerator is designed to operate at a high enough temperature range (> 1,400 °C) and is equipped with effective and internationally acceptable emissions management system in place.

- Expensive to en-place

- Operating temperature range must be above 1,400 °C to ensure that harmful chemicals (dioxins, furans) are not emitted into the atmosphere as bi-products of combustion.

- The incinerator must be equipped with expensive emissions management system.

- Logistical problems (bad roads, insecurity, fuel costs, etc)

- Adequate inventory and location of equipment/waste must be available.

3 On-site use of BAT/BEP low cost technologies (bioremediation)

- Reasonably Cheap- Proven efficacy in research

situations- Readily available

- Appropriate research on bio-technology options available and effective in-country has not been carried out

- Technology has not been used

Table 6.1: Alternatives Matrix



on a wide scale locally and internationally, so as to guaranty optimal efficacy.

4 Export of Potentially PCBs contaminated Equipment/waste to another country

- Guaranty of ESM of the wastes - Expensive- Development of

in-country/regional capacity is hampered

- Contaminated soils still have to be managed locally.

5 Long-term storage of potentially PCBs Contaminated equipment (until ESM is feasible in-country)

- Allows for proper planning and choice of technology option.

- Environmentally acceptable- Builds in-country analytical and

disposal technology capacity- Ensures that other countries in the

region with less capacity/capabilities can utilize the facilities

- Preserves funds and will ultimately act as a source of income for the country.

- Proper logistical arrangements so as to ensure environmentally sound facilities for inventory, transport, and storage must be en-placed

- Expensive- Adequate training for

personnel.



6.2 Impact Assessment

This section identifies environmental/health impacts and suggests mitigation measures for ensuring sustainability and minimizing the adverse impacts of poor handling, storage and disposal of PCB contaminated equipment, oils and wastes on the environment and occupational activities of personnel involved in PCB related activities

6.2.1 Impact/Hazard Prediction MethodologyThe method adopted for the evaluation of the potential impacts of component activities (emphasis: sub-components 2b and 2c) should consider the anticipated/observed biophysical, social, and health impacts, their interactions among the environmental components, and their sensitivities.

6.2.2 Rating of Impacts/Hazard

Five steps can be followed sequentially in order to rate the impact of anticipated and observed environmental and risk hazards as shown below.

Stage 1: Impact/Hazard Identification

Interaction between project activities and environmental sensitivities

Stage 2: Qualification of Impacts/Hazard

• Positive/negative

• Direct/indirect

• Duration:

• Permanent (long term)/temporary (short term)

• Magnitude: local or widespread

• Reversible or irreversible

Stage 3: Rating of Significance

• Likelihood

• (High, 80-100%, i.e. very likely; Medium high, 60-80%, i.e. likely; Medium, 40-60%, i.e. possible; Medium Low, 20-40%, i.e. unlikely; Low, 0-20% i.e. very unlikely)

• Consequence

• (Extreme, Great, Considerable, Little, Hardly Any)

Stage 4: Degree of Significance of Impact/Hazard

Four degrees of significance:



• Major

• Moderate

• Minor

• Negligible

Stage 5: Impact/Hazard Table

• Lists each impact, its source and its rating

Step 1: Identification of Potential Impacts

The environmental and social sensitivities likely to be affected by component activities (sub-component 2b and 2c) will include the following:

Surface water quality Hydrogeology Air quality Soil quality Flora and fauna Human habitations and heritage Public Health Occupational health and safety Existing adjacent structures Occupation

Steps 2 and 3: Qualification of Impact/Hazard.

These are based on two assessment characteristics:

Step 2: Likelihood of occurrence – this is an assessment of the probability of the effect occurring.

Step 3: Potential consequence – this is the actual result and scale that an effect might have.

The application of each of the two characteristics is described in Table 6.2.

Table 6.2: Likelihood of Occurrence

Impact/Hazard probability Likelihood Frequency

High probability (80-100%) A very likely impact Very frequent



impacts

Medium high probability (60-80%) A likely impact Frequent impacts

Medium probability (40-60%) A possible impact Occasional impact

Medium low probability (20-40%) An unlikely impact Few impacts

Low probability (0-20%) A very unlikely impact Rare impacts

The magnitude of the potential changes to the environment caused by a hazard, and the level of sensitivity of the receiving environment determine the potential impact of the activity. This is shown in Table 6.3.

Table 6.3: Potential Consequences Classification Matrix

Magnitude of Effect

Receptor sensitivity

Low change Medium change High change

Low receptor sensitivity

Trivial effect Slight effect Substantial effect

Medium receptor sensitivity

Slight effect Substantial effect Big effect

High receptor sensitivity

Substantial effect Big effect Massive effect

The potential consequence and its effects are shown in Table 6.4.

Table 6.4: Potential Consequence

Potential Consequence Effect

Extreme consequence A massive effect

Great consequence A big effect

Considerable consequence A substantial effect

Little consequence A slight effect

Hardly any consequence A trivial effect

Step 4: Degree of significance



Table 6.5 shows the impact significance with associated impact rating.

Table 6.5: Degree of Impact Significance

Impact Significance Impact Rating

Major significance Major impact

Moderate significance Moderate impact

Minor significance Minor impact

Negligible significance Negligible impact

Step 5: Impact Assessment Matrix

The potential impacts were evaluated using the Impact Assessment Matrix shown in Table 6.6.

Table 6.6: Impact Assessment Matrix

6.2.3 Determination of Associated and Potential ImpactsThe results of the evaluation of the interactions between component activities and the above listed environmental sensitivities and the impacts on biophysical, social and health components are demonstrated in Table 4.6.

Potential consequencesLikelihood

Positive

High

Medium highMedium

Medium lowLow

Hardly any

Moderate

Minor

Minor

Negligible

Negligible

Moderate Moderate Minor

Minor

Negligible

Major

Moderate

Moderate

Minor

Minor

Great

Major

Major

Moderate

Moderate

Minor

Extreme

Major

Major

Major

Moderate Moderate

Negative Little Considerabl

e





upgrading of laboratories for analyzing PCBs in oil, water and soil samples.

Environmental Component Affected

Potential Impact/Hazard Description Likelihood Consequences

refurbishment of physical Soil, Vegetation, Beneficial environmental micro and macro organisms, animals, surface and ground waters

Alteration of natural geophysical properties of soil

Direct, Negative Short/Long-term, Local, Reversible/Irreversible

Medium high Considerable

Destruction of flora and fauna habitats and bioaccumulation


High Extreme

Dust production, Noise pollution, Solid waste generation, Occupational H&S

Direct, Negative Short/Long-term Local, Reversible/Irreversible


mechanical equipment and Soil, Health/Safety Work related accidents Direct, Negative Short term,

Local, ReversibleLow Considerable

Weight-induced ground compaction


Medium low Little

Standard laboratory based Health/Safety Work related accidents Direct, Negative Short term, Local, Reversible

Medium high Major

Water bodies, adjacent structures, human and animal activities

Alteration of natural geophysical properties of soi,l Destruction of nearby animal and plant aquatic habitat, forced resettlement, contamination of surface and ground waters.


Medium high Major

Accumulation of dust in the air Direct, Negative Short/Long-term Local, Reversible/Irreversible


Identification and possible enhancement of interim

Environmental Component Affected

Potential Impact/Hazard Description Likelihood Consequences

Soil, Vegetation, Beneficial environmental

Alteration of natural geophysical properties of soil

Direct, Negative Short/Long-term, Local,


Table 6.7 Associated and Potential Impacts

Table 6.8 Associated and Potential Impacts



micro and macro organisms, animals, surface and ground waters

Reversible/Irreversible

Destruction of flora and fauna habitats and bioaccumulation


High Extreme

Dust production, Noise pollution, Solid waste generation, Occupational H&S

Direct, Negative Short/Long-term Local, Reversible/Irreversible


Cleaning oil leaks from Soil, groundwater, Health/Safety

Work related accidents Direct, Negative Short term, Local, Reversible

Low Considerable

Contact dermatitis Direct, Negative Short/Long-term, Local, Reversible/Irreversible

Medium low Little

Sorting and stacking up of disused oil circuit breakers, Current transformers and voltage transformers

Health/Safety Work related accidents Direct, Negative Short term, Local, Reversible

Medium high Major

Contamination of groundwater via seepage

Direct, Negative Long term, Local, Reversible

Medium high Major

Hiding places for dangerous animals such as snakes and other reptiles

Direct, Negative Long term, Local, Reversible


Haulage and transportation Health/Safety Work related accidents Direct, Negative Short term, Local, Reversible

Low Considerable

Weight-induced ground compaction


Medium low Little

Project Component Activities Negative Impacts Mitigation Measures Monitoring

What parameter is to be monitored

Where will

be monitored

How is it to be monitored

Component 1- Capacity Building for PCB Management

1. Comprehensive review of current hazardous waste management regulations.

2. Development and incorporation of a new regulatory framework that will specifically address PCBs.

3. Training and awareness (including stakeholders workshop).

None None Component implementation

All around the country Integral project instruments

Component 2- Design, development and

2a. Development of guidelines for the identification of all equipment and

None None Guideline development Locations for component activity guideline

Observation and guidance

Table 6.9: EMP SUMMARY- Mitigation, Monitoring, Institutional Responsibility



implementation of environmentally sound management (ESM) for online and offline electrical

wastes consisting of/contaminated with PCBs.

development WB-safeguards

2b. Identification and upgrading of laboratories for analyzing PCBs.

Ground-slides, Dust production, Solid and other waste type production, Noise, Damage of ecology and natural resource resulting from poor handling of possible PCBs containing samples and materials.

General occupational health and safety prone risks.

- Check collapse prone areas by undertaking confirmatory tests.

-Provision of hydrants or sprinklers

-Use of PPEs

-Preparation of waste segregation procedures

-Implementation of occupational safety and health protocol

Site-works Site location Observations/

checklist compliance

Project Component Activities Negative Impacts Mitigation Measures Monitoring

What parameter is to be monitored

Where will

be monitored

How is it to be monitored

equipment and potentially contaminated sites

(This component has 6 sub-components with distinct activities)

2c. Identification and possible enhancement of interim storage locations.

Dust and noise production during excavation and earthworks, Visual impacts

Destruction and loss of native flora and fauna during construction, Oil leakages during equipment transport, Damage to ground water resulting from seepages from stored potentially PCBs contaminated wastes and equipment.

Use of hydrants, Construction of concrete floors.

Design and develop effective surface and ground water control measures.

Development of Ste-Specific Safety Management Plans

Site-works Site location Site-Specific Safety Management Plan



2d. Waste oil management and transformer maintenance guideline.

None None Guideline development Locations for component activity guideline development


WB-safeguards

2e. Development of strategies for PCB management and containment at the national level

None None Strategy development process

Locations for sub-component strategy development

Expert guidance

WB-safeguards

2f.Development of guidelines for characterization and risk assessment of contaminated sites

None None Guideline development Locations for component activity guideline development


WB-safeguards

Component 3- Baseline national inventory of PCBs and PCB containing equipment, and development of a national PCB management plan

Component 4- Monitoring and evaluation

Activities under this component will include the establishment of a data base for PCB containing equipment and wastes in 15 additional states and the development of comprehensive methodology for conducting inventories

None None Methodology for inventory, data base development and upgrading

Planning and Site locations

Expert guidance

Integral instruments

Monitoring progress of project and evaluating effectiveness of project implementation

None None Monitoring and evaluating effectiveness

Environment of component execution

Monitoring framework and records



CHAPTER 7:OVERVIEW OF ENVIRONMENTAL ASSESSMENT PROCESS

7.1 Stakeholder Participation In the course of preparing this ESMF, extensive consultations were held with key stakeholders including officials of the federal ministries of environment and power as well as their agencies. Throughout the project implementation, stakeholders’ participations and discussions will be of primary importance and will continue. Policy and Overall Project Direction: The Federal Ministry of Environment (FMEnv) working with associated ministries and key stakeholders will create an Inter-ministerial Steering Committee (ISC) Workshops, information dissemination will be ensured to improve and achieve a sound environmental management regime for the project. NGOs’ and relevant stakeholder government agencies will be part of the public awareness and environmental education programmes. In the course of preparing this ESMF, consultations were held with key stockholders including the officials of the federal ministry of environment and other relevant agencies. This consultation that has already started during project consultation shall continue during project implementation. To this end, the following Consultation Strategies will be followed:

The focus of this public involvement program/plan is to inform the public and invite input

relating to the plan and its implementation. As elements of the plan proceed from planning

into execution, the Nigeria PCB project objective will be to maintain the public awareness

and understanding of the plan. The implementing agencies (FME, PHCN-PMU etc) shall

execute a program comprising strategic elements to accomplish the public consultation

objective. A comprehensive public awareness program will include the following:

- Develop and distribute a project newsletter

- Organize seminars and workshops

- Develop and maintain a project web site

- Develop radio and television adverts

- Prepare project press releases



- Prepare posters and erect billboards

The level of stakeholder involvement will be based on the project phase, location and

expected outcome.

The extent of stakeholders’ involvement would be based on the following:

• the project is likely to have significant impacts, that is, high impacts in one area/location, or

relatively

small impacts spread out over a large area; and

• the project involves significant issues, that is, the wider stakeholder may be affected..

Table: Outlay of major stakeholders and expected responsibilities.

Stakeholder Agency Responsibilities

Federal Ministry of Environment Overall in-charge of implementing the project

Power Holding Company of Nigeria (PHCN) Implementation of key project components in which it has technical and personnel advantages

Print and electronic media Public awareness

NGOs Public awareness/Policy issues

National Environmental Standards Regulations Enforcement Agency

Capacity building, Legislative activities & Policy issues

7.2 Public Consultation and DisclosureThe preparation of the EA documents will require stakeholder/public consultation and disclosure. The characteristics of stakeholder/public consultation and disclosure depend on the component and site-specific activity.

The overall objective of the Communications Strategy is an effective information exchange on POPs/PCBs management among policy and decision-makers, electricity industry and professional users and the general public, especially those living/working in the vicinity of potentially PCBs contaminated equipment and wastes storage facilities

Specifically, this strategy aims to:(i) Increase awareness and understanding of stakeholders on toxic chemicals such as POPs/PCBs -- their health and environmental risks, economic and social costs and the alternatives to them.



(ii) Mobilize policy and decision-makers to actualize government’s commitments to the Stockholm Convention as specified in the National Implementation Plan on POPs management, reduction and elimination.(iii) Define the process for conducting consultation and information disclosure for those involvedin PCBs/POPs management, reduction and elimination.(iv) Promote public participation in addressing the health and environmental effects of PCBs/POPs.

7.2.1 Institutional Arrangement: No proposed subproject can be implemented for the Nigeria PCB management project until the required EMP or EIA, has been approved by the cognizant agency. For any sub-project requiring an EIA, approval from FME is the first formal step. FME has the discretion to require a public hearing as part of its review process, and to refer projects to a Joint Review Panel when it deems that to be appropriate. FME’s review report is a public document, and the EIA Act requires that it be provided to any interested party. The PMU and the Bank will also review and approve EIAs for subprojects, after FME has issued the certificate that indicates satisfactory completion of the environmental assessment. The Environmental Officer to be domiled in the PMU is responsible and accountable for all safeguards issues of the project. The key players in implementing the proposed activities are the Federal Ministry of Environment (FMEnv) and Power Holding Company of Nigeria (PHCN). They shall ensure that the PCBs management project’s implementation is in accordance with the WB safeguards policies, and Nigeria’s environmental and social laws and regulations. The Environmental Officer will be supported by consultants to be engaged on need basis. In addition the safeguards specialists in the World Bank team will provide additional guidance as required.

7.2.2 Institutional Capacity for Environmental Management. The ESMF includes a

section on the capacities of the main actors in environmental management for Nigeria PCB

management project. Under the project, the Environmental officer’s role will expand to

include oversight functions in compliance with the ESMF. The Environmental officer will be

monitoring the environmental indicators to keep PMU and the Bank informed on safeguards

performance. For this purpose, it is recommended that the Environmental officer receive

additional training to cover environmental and social aspects of PCB management, Bank

policies.

7.2.3 Monitoring and Evaluation: Monitoring will be conducted to ensure the project's compliance with program level mitigation measures, appropriate specification and inclusion of applicable operational and regulatory standards in bidding and contractual agreements, as well as to evaluate the effectiveness of operational controls and other measures intended to mitigate potential impacts of sub projects.



Quarterly Monitoring Reports shall be issued by the Environmental Officer on compliance with mitigation measures indicate in the ESMF and EMPs. As may be applicable, monitoring reports shall provide information on:

- Overview of PPP transactions - EA Category of each transaction - Environmental due diligence findings - Stakeholder interaction summary - E & S actions required of contractors in charge of civil works, inventory,

evacuation and on site management of PCBs - Areas of non compliance and proposed corrective actions

7.2.4 TrainingAdequate training on general aspects of PCBs management will be a major requirement for understanding, planning, implementation, sustainability and output delivery of all project components.

Trainings will include but not limited to -

Component 1:

Basic fundamentals on PCBs chemical structures, congeners, characteristics, environmental and health risks posed commercial names.

National and international Legal and regulatory frameworks for hazardous chemical management.

International best practices in PCBs management; identification, sorting and storage. Conventions and international parties to control and management of PCBs and other

POPs. EMP training

Component 2:

Introduction to Occupational health and safety (OHS) Hazard control and analysis Conducting job hazard analysis (JHA) Safety supervision and leadership Safety management system evaluation Emergency action plans Preventing work place violence Fall protection program EMP training

Component 3:

Methodology development for conducting inventories of PCBs and PCBs containing equipment.

Use of PPEs. GPS and GIS; Standard operations manual. EMP training



Component 4:

Standard procedures and checklist characterization for evaluating component performance in PCBs management.

Report writing; language and communication fundamentals. Quality assurance, quality control and assessment procedures. EMP training Basics of project management; Project scope, implementation, time, resource, cost,

procurement and risk management. Ergonomics EMP training



Chapter 8: COSTS AND BUDGETING FOR ESMF IMPLEMENTATION

Most environmental management measures are an integral part of the sub-project design and operations, thus, budget for these responsibilities are allocated in the total sub-project cost for each component sub-project activities.

Preparation and Disclosure of Site Specific EIAs/EMPS: As already indicated, at the time of preparing this project the locations and potential adverse impacts were not known in sufficient details. However, during project implementation when the project sites will have been identified, site specific EIA or EMPs will be prepared and disclosed prior to the commencement of any civil work. The preparation of these safeguards instrument is estimated to cost $200,000.

Capacity Building: A training program covering the four (4) project components may be undertaken for a five (5) month period. The estimated cost per month for the salary and living expenses of an international resource person/trainer is estimated at US$25,000/month, or a total of US$125,000.

Monitoring and Evaluation: Both the ESMF and site specific EMPs will have to be vigorously monitored to ensure compliance. To this end the sum $100000 estimated for monitoring and evaluation

Total Cost for ESMF Implementation: Thus, from the above breakdown, the sum of $ 425,000 is estimated for the implementation of the ESMF including the preparation of EMPS, capacity building and monitoring.



-ANNEX 1-

ENVIRONMENTAL GUIDELINES FOR CONTRACTORS

The following guidelines should be included in the contractor’s agreements:

Installation of the work site on areas far enough from water points, houses and sensitive areas.

Sanitary equipments and installations Site regulation (what is allowed and not allowed on work sites) Compliance with laws, rules and other permits in vigor. Hygiene and security on work sites Protect neighboring properties Ensure the permanence of the traffic and access of neighboring populations during the

works to avoid hindrance to traffic Protect staff working on work sites Soil, surface and groundwater protection: avoid any wastewater discharge, oil spill

and discharge of any type of pollutants on soils, in surface or groundwater, in sewers, drainage ditches or into the sea.

Protection of the environment against noise: reduce work site noise likely to seriously disturb neighboring people.

Protect the environment against exhaust fuels and oils Protect the environment against dust and other solid residues Waste management: install containers to collect the wastes generated next to the areas

of activity. Degradation/demolition of private properties: inform and raise the awareness of the

populations before any activity of degradation of gods. Compensate beneficiaries before any demolition.

Use a quarry of materials according to the mining code requirements Compensation planting in case of deforestation or tree felling No waste slash and burn on site Speed limitation of work site engines and cars Allow the access of Public and emergency services Organize the storage of materials on the public highway Parking and displacements of machines Footbridges and access of neighbors Signaling of works Respect of cultural sites Reclamation of the sites at the end of the works Dispose safely of asbestos Consider impacts such as noise, dust, and safety concerns on the surrounding

population and schedule construction activities accordingly; Protect soil surfaces during construction; Ensure proper drainage; Prevent standing water in open construction pits, quarries or fill areas to avoid

potential contamination of the water table and the development of a habitat for disease-carrying insects;



Select construction materials in a sustainable way, particularly wood; Control and clean the construction site daily; During construction, control dust by using water or through other means; Provide adequate waste disposal and sanitation services at the construction site; Dispose of oil and solid waste materials appropriately. Preserve natural habitats along streams, steep slopes, and ecologically sensitive areas Develop maintenance and reclamation plans and restore vegetation and habitat.



-ANNEX 2-

EIA /ESIA TERMS OF REFERENCE

Introduction and context

This part will be completed in time and will include necessary information related to the context and methodology to carry out the study.

Objectives of study

This section will indicate (i) the objectives and the project activities; (ii) the activities that may cause environmental and social negative impacts and needing adequate mitigation measures.

Tasks

The consultant should realize the following:

Describe the biophysical characteristics of the environment where the project activities will be undertaken; and underline the main constraints that need to be taken into account at the field preparation, during the implementation and exploitation/maintenance of equipments.

Assess the potential environmental and social impacts related to project activities and recommend adequate mitigation measures, including costs estimation..

Review political, legal and institutional framework, at national and international level, related to environmental, identify the constraints and suggest recommendations for reinforcement

Identify responsibilities and actors for the implementation of proposed mitigation measures

Assess the capacity available to implement the proposed mitigation measures, and suggest recommendation in terms of training and capacity building, and estimate their costs.

Develop a Environmental Management Plan (EMP) for the project. The EMP should underline (i) the potential environmental and social impacts resulting from project activities (ii) the proposed mitigation measures; (iii) the institutional responsibilities for implementation; (iv) the monitoring indicators; (v) the institutional responsibilities for monitoring and implementation of mitigation measures; (vi) the costs of activities; and (vii) the calendar of implementation.

Public consultations. The EIA/ESIA results and the proposed mitigation measures will be discussed with population, NGOs, local administration and other organisations mainly involved by the project activities. Recommendations from this public consultation will be include in the final EIA or ESIA report.

Plan of the EIA report

- Cover page- Table of contents- List of acronyms- Executive summary - Introduction



- Description of project activities - Description of environment in the project area - Description of political, legal and institutional framework- Description of methodology and techniques used in assessment and analyse of project

impacts. - Description of environmental and social impacts for project activities- Environmental Management Plan (EMP) for the project including the proposed

mitigation measures; the institutional responsibilities for implementation; the monitoring indicators; the institutional responsibilities for monitoring and implementation of mitigation; Summarized table for EMP

- Recommendations- List of persons / institutions meet

Duration of study

The duration of study will be determined according to the type of activity

Supervision of study

The consultancy will be supervised by the Environmental Officer of the PMU


PCB Management Project, Nigeria

Documents