Western Range DSO Iron Ore Project - ArcelorMittal

Western Range DSO Iron Ore Project

Environmental and Social Impact Assessment

Overview

September 2010

This Environmental and Social Impact Assessment (ESIA) and

Environmental and Social Management Plan (ESMP) Report relates to the

Phase 1 (DSO Mining) of a wider programme of development of Iron Ore

Mining at Tokadeh, Gangra and Yuelliton Mountains in Nimba County,

Liberia, and transportation of such ore for export via Buchanan Port using

a 255km long existing railway. The DSO mining involves the excavation,

crushing and screening of up to 50m depth of soil and rock over an area of

approximately 1.8 km2 and the production of an estimated 4 million tonnes

per year over a period of 4 to 5 years. It is anticipated that approximately

500 ha of agriculture and forest will be taken out of current production by

the actual mine and the attendant infrastructure. Township development

will take place at Yekepa and Buchanan, requiring housing refurbishment

and the provision of services, including drinking water, power, sewerage

treatment and waste management. Two airfields are likely to be

reinstated, close to Yekepa and Buchanan respectively. A railway

maintenance camp will operate at Greenhill in Bong, part way along the

railway. Mining at Tokadeh took place between 1973 and the early 1990‟s

when iron ore mining in the East Nimba Range was carried out by LAMCO

and then LIMINCO. Gangra and Yuelliton are green field sites as far as

mining activity is concerned, though degradation has occurred due to past

road construction and mine survey work. Significant legacy pollution

effects remain from the earlier mining period, including especially the

pollution to water courses.

ArcelorMittal Liberia Limited


Environmental and Social Impact Assessment Overview September 2010

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Overview of the Project

The main report (Volume 1) contains a summary of the findings of the environmental and social

impact assessment, the recommendations for mitigation and the framework ESMP. Volume 2

contains a legal and administrative framework review and Volumes 3, 4 and 5 contain the

baseline, impact assessments and detailed mitigation proposals for the physical environment, the

biological environment and the socio-economic environment respectively. Some relevant

standards for ESMP implementation and a Mine Closure Plan are given in Volumes 6 and 7

respectively.

The proposed mine sites are close to Mount Nimba, and can be considered as part of the wider

Nimba Range. From a global conservation perspective, the Nimba Range is among the most

important areas in Africa, with numerous endemic species, many of them globally threatened.

There are multiple threats to the biological integrity of the area. In addition to current plans for

iron ore mining, there are also pressures from land clearance for agriculture, uncontrolled fires,

unsustainable hunting and logging, and the legacy of past mining operations.

The physical environmental impacts associated with the project relate primarily to the removal of

the mountain tops at Tokadeh, Gangra and Yuelliton. These form high value landscape features

that will not be replaced, although provision has been made in the Mine Closure Plan for land

surface reinstatement. Drainage is another potentially significant impact receptor. The potential to

pollute watercourses downstream of the mine is high, and this will have potential knock-on

effects associated with water usage by the local community and also riverine biological habitats

(see below). Potential sources of mine sediment include landslides and erosion from mine

surfaces, erosion of stream channels and material removed from stockpiles and waste dumps.




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The intense, heavy and prolonged rainfall in the Nimba area is able to collect, transport and

transfer considerable volumes of sediment downstream. To avoid and mitigate this, a

comprehensive plan of protection and retention is required with regular maintenance and effluent

monitoring. With these measures in place these impacts should reduce to acceptable levels as

long as the investment is made in the control of materials at source and the design, construction

and maintenance of the protective structures. Groundwater, watercourses and habitats can all be

polluted significantly from spills and leakages from a variety of project sources of toxic or

hazardous substances. Assuming that international industry standards are put in place to

manage, protect and contain these, then the potential effects can be avoided or minimised.

Overview of the Mine Area

The silhouettes of Mounts Beeton, Gangra and Yuelliton from the old Nimba mine




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Groundwater conditions in the project area are considered to be controlled by a shallow aquifer

in the underlying basement rocks. There is very little information on the yield and quality of this

aquifer. However, the aquifer in the Buchanan area was exploited during the LAMCO/LIMINCO

mining period. Investigations will need to be undertaken to confirm these parameters. In the

mine area special consideration will need to be given to the quality of groundwater being used

by local hamlets and villages. The intention is to provide additional abstraction facilities for these

communities where required, and therefore quality checks and monitoring will be needed. Other

aspects concerning the physical environment relate to air quality and noise. There will be noise

generated at the Tokadeh rail head that will require mitigation in terms of hoarding and local

bunding for example, and noise barriers will be required to reduce noise from railway operation

close to Sanniquellie Hospital to acceptable levels. A noise barrier will also be required at the

edge of the port area to reduce received noise levels at the adjacent Buchanan town. Dust is

already a significant issue at certain times of year, and mining operations, quarries, borrow pits

and access road construction and operation will contribute more significantly. Standard

measures for dust suppression will need to be deployed.

A mountain stream on Mount Tokadeh The LAMCO-damaged Dayea River near Yekepa

The Gangra-Yuelliton and Tokadeh ridges lie on the eastern margin of the Forestry

Development Authority‟s – proposed West Nimba Protected Area (WNPA)1. This is a largely

forested area remaining mostly intact that contains rich biodiversity and many examples of rare

and globally threatened animals and plants. The DSO mine footprint, according to the July 2010

FDA boundary, lies to the immediate east of this area. Nevertheless, it contains important

examples of faunal species that are globally threatened. Some groves of forest within the DSO

footprint contain tall, close canopy trees and several examples of Black Star (very narrow global

range with high priority for conservation) and Gold Star (globally fairly restricted) species have

been found. Black Star species are top ranking in terms of global rarity. However, a

standardised global hotspot index derived from the representation of these globally rare species

- the Genetic Heat Index (GHI) - of the botanical assemblage in the DSO footprint is described

as being „warm‟ rather than „hot‟ and the bioquality (which is measured by the GHI) of the DSO

area is no better or worse than that outside of it. Constraints maps have been produced for both

DSO mine areas that indicate important habitats that should be avoided or preserved wherever

possible. This would mean locating stockpiles, waste dumps and in-pit access roads specifically

to avoid these areas. The current arrangement of these features is such that many areas are

1 Proposed forest protection boundaries have changed over recent years, and some confusion exists over boundaries and proposed

designations, but this statement is based on the most recent mapping from the FDA.




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already avoided. Adherence to the constraints maps will reduce the effects of the DSO mining,

but inevitable deterioration of habitat will still occur. Downstream effects on riverine habitats,

including swamps, could be more severe than the removal of habitat at the DSO mine itself, with

endangered species, such as the Lugbe River Crab and the Nimba Otter Shrew considered

likely to inhabit such areas. This reinforces the criticality of ensuring control on sediment, runoff

and toxic polluting substances and the prevention of pollution to any part of the aquatic

environment. Noise and other mine edge effects will lead to a reduction in habitat quality

adjacent to the mine, and some birds and mammals are likely to move away from the area.

Mount Yuelliton from an exploration access track on Mount Gangra

Some patches of good (and some “hot”, i.e. high bioquality) forest remain outside of the DSO

mine area and these should be protected wherever possible. It is the intention of ArcelorMittal to

remain an active stakeholder and supporter of the development and implementation of the

proposed West Nimba Protected Area. It is the conservation of this wider area that is of utmost

ecological priority and will require the control of bushmeat hunting, slash and burn agriculture,

logging, road construction and mineral exploration. Improved agro-forestry activities in existing

farms around the protected area should be promoted. As an important part of this protection it is

considered imperative to prevent any runoff or material spill, access clearance or other

disturbance to the slopes to the south and west of Tokadeh and to the west of Gangra-Yuelliton.

Even very small, isolated patches of forest away from the proposed West Nimba Protected Area

(e.g. on small hills in the lowlands west of Mount Gangra and riparian strips throughout the

landscape) have considerable biodiversity and local use-value as forests, and should, wherever

possible, be protected. Support for the improvement of agro-forestry practices and for forest

restoration will require an early start developing a nursery for indigenous, especially rare, useful

and vigorous pioneer plants. This in turn will involve collecting a wide range of local genetic

material and development of the resources that such a nursery will require in coming years.




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Some of the rich biodiversity of the forests around the proposed mine sites

The project will result in a significant increase in human population in the area (workforce, job-

seekers and other migrants) and this will place increased pressure on the forest and its

resources. There should be a zero tolerance policy on bushmeat hunting among company

employees, contractors and suppliers. A public awareness campaign will need to be put in place

to educate the public as to the biodiversity value of the wildlife and to find alternative sources of

livelihood (see below).

Elsewhere in the project area, ecology considerations relate primarily to the potential for a

railway wagon car spillage of iron ore into the St John River or its tributaries and the potential to

pollute sea water and marine life in the port should a spillage take place of iron ore, fuel or any

other toxic substance. These potential sources of risk can be minimised and managed through

adherence to appropriate operating standards and the implementation of an emergency

preparedness plan. Further along the coast at Buchanan, there are known to be turtle nesting

sites, and these will require protection from hunting.

Fallow land a few years after cultivation Firewood and other forest products




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Impacts to the socio-economic environment relate principally to the involuntary resettlement of

people from farms in the mine area and from some areas of Yekepa to house company

employees. In the mine footprint approximately 140-150 farms will be affected and farmers and

their dependents will require involuntary resettlement. In Yekepa, involuntary resettlement is

expected to involve slightly over 500 people. The most significant outcome of this would be the

loss of livelihoods, increased vulnerability to disadvantaged groups and increased pressure on

scarce land and resources elsewhere. The company is in the process of undertaking a

Resettlement Action Plan and Compensation Programme, and this does not therefore form part

of this ESIA - ESMP. However, it is implicit that this programme be fully inclusive of all social

groups and be based on a case-by-case assessment, leading to the provision of equal or

improved sustainable livelihoods. As part of this ESIA - ESMP a Community Development

Programme has been devised that includes local handicraft and small scale economic

development initiatives to assist in the development of alternative sustainable livelihoods. It also

includes an agricultural intensification programme whereby investments are made in the

provision of land and resources to increase agricultural activity in other areas to enable

displaced farmers to be accommodated.

A typical weekly market in a small town in the project area

Other issues relating to the removal of mountainsides for mining concern the loss of some

cultural heritage sites. This is currently the subject of a separate study by the company, but it is

important to base the approach on avoidance and the provision of culturally acceptable

alternatives. Managed access will need to be arranged to those sites outside of the mine area

but within the security zone. This perimeter safety zone will also exclude access to some of the

sites for harvesting non-timber forest products and medicinal plants. Controlled access should

be provided to these areas where they are outside of the mine footprint and alternative provision

should be given for the propagation of these and other plants of ecological importance in

nurseries and other forest areas for use by the affected communities.




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Other socio-economic considerations relate to the townships of Yekepa and Buchanan and the

need to provide safe and suitable living conditions in terms of human health, social vulnerability,

control on alcohol, drugs and violence, provision of potable water supplies, and safe and

adequate sewerage systems and waste disposal. Food security could be an issue, and this will

require to be assessed. Safety to the workforce and the public is critical across the entire

project. This can relate to accidents at the workplace, traffic accidents and railway accidents,

and all measures should be taken to prevent them and contain their effects when they do occur.

These are to include training in the use and handling of materials, containment and clean up

measures in the event of a spillage, the use of personal protective equipment, hazard warning

signs, prevention of theft, safety awareness campaigns and measures to reduce traffic

accidents, including speed control, access control, audible and visible warnings and public

awareness campaigns.

The ESMP identifies the various precautionary, mitigation and improvement measures required

to achieve the above and sets out a number of Management Plans and Programmes. The

environmental and social development staff of ArcelorMittal will be required to oversee the

implementation of the ESMP and a number of additional studies will be required to inform the

details of the required mitigation. It is important that social development staff include

representatives of the indigenous groups and have Mano speaking capacity.

So far, this summary has focused on identifying and addressing potential adverse effects.

Opportunities for environmental, agricultural and social improvement are also present. These

include the provision of employment, the improved facilities to be installed at Yekepa and

Buchanan, and the opportunities for training and skills development among the workforce, and

provision of improved schooling and scholarships for further education. The project will generate

the need for service provision and this will encourage local service sector enterprise to develop.

The company can encourage this and provide business training in the process. It will be

important to ensure economic diversification away from iron ore, in places like Yekepa for

example, to sustain the economy and social provision once iron ore mining ceases. Other

opportunities for improvement include the development of the proposed WNPA (see above) and

the strengthening of the East Nimba Nature Reserve. Although not a requirement of the Mineral

Development Agreement (MDA), the company also has the opportunity to mitigate some of the

legacy issues surrounding earlier mine workings.

Project mitigation measures during the infrastructure rehabilitation phase have already helped to bring development improvements to rural Liberia

Western Range DSO Iron Ore Project - ArcelorMittal

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