world bank documentdocuments.worldbank.org/curated/en/520631468775588865/... · 2016-07-17 ·...

E438

ENVIRONMENTAL ASSESSMENT AND ENVIRONMENTAL POLICYFRAMEWORK EVALUATION OF THE NIGERIA POWER

TRANSMISSION DEVELOPMENT PROJECT

Submitted on Behalf of.

National Electric Power Authority of NigeriaTransmission Development Project

Project Management UnitNEPA IIQ, Area 3, Garki, Abuja-Nigeria

Transmission Div., I' Floor Room 04Attn. Mr. B.O. Adeyemo

Submitted by:

Golder Associates Inc.44 Union Blvd., Suite 300

Lakewood, CO 80228

Distribution:

2 Copies - NEPA Project Management Unit3 Copies - World Bank2 Copies - Golder Associates Inc. Li:

February 5, 2001 003-2204

Pub

lic D

iscl

osur

e A

utho

rized

Pub

lic D

iscl

osur

e A

utho

rized

Pub

lic D

iscl

osur

e A

utho

rized

Pub

lic D

iscl

osur

e A

utho

rized

Pub

lic D

iscl

osur

e A

utho

rized

Pub

lic D

iscl

osur

e A

utho

rized

Pub

lic D

iscl

osur

e A

utho

rized

Pub

lic D

iscl

osur

e A

utho

rized

Golder Associates Inc.44 Union Boulevard, Suite 300Lakewood, CO USA 80228 GolderTelephone (303) 980-0540 AssociatesFax (303) 985-2080

ENVIRONMENTAL ASSESSMENT AND ENVIRONMENTAL POLICYFRAMEWORK EVALUATION OF THE NIGERIA POWER

TRANSMISSION DEVELOPMENT PROJECT

Submitted to:

National Electric Power Authority of NigeriaTransmission Development Project

Project Management UnitNEPA IIQ, Area 3, Garki, Abuja-Nigeria

Transmission Div., I' Floor Room 04Attn. Mr. B.O. Adeyemo

Submitted by:

Golder Associates Inc.44 Union Blvd., Suite 300

Lakewood, CO 80228

Distribution:

2 Copies - NEPA Project Management Unit3 Copies - World Bank2 Copies - Golder Associates Inc.

February 5, 2001 003-2204

OFFICES IN AUSTRALIA, CANADA, GERMANY, HUNGARY, ITALY, SWEDEN, UNITED KINGDOM, UNITED STATES

February 2001 -i- 003-2204

TABLE OF CONTENTS

EXECUTIVE SUMMARY ..................................................... ES-1

1.0 INTRODUCTION AND OBJECTIVES OF THE ENVIRON-MENTALASSESSMENT .................................................................... 1

2.0 POLICY, LEGAL, AND ADMINISTRATIVE FRAMEWORK ......................... 32.1 Environmental Assessment in the Republic of Nigeria ................................. 32.2 Environmental Assessment for World Bank Funded Projects ......................... 4

2.2.1 World Bank Sectoral Guidelines .................................................... 42.2.2 World Bank Cross Sectoral Policies ................................................ 52.2.3 World Bank Numerical Standards .................................................. 5

3.0 PROJECT DESCRIPTION ....................................................... 73.1 Project Investment Component 1 ......................................................... 73.2 Project Investment Component 2 ..................................................... 83.3 Project Investment Component 3 ..................................................... 8

4.0 DESCRIPTION OF THE AFFECTED ENVIRONMENT ............................... 104.1 Oshogbo Substation ........................................................ 10

4.1.1 Property Description ......................................................... 104.1.2 Existing Facilities ........................................................ 114.1.3 Existing Environmental Management Issues .................................... 11

4.2 Kano Substation ........................................................ 134.2.1 Property Description ........................................... ............. 134.2.2 Existing Facilities ........................................................ 144.2.3 Existing Environmental Management Issues .................................... 14

4.3 Onitsha Substation ........................................................ 154.3.1 Property Description ......................................................... 154.3.2 Existing Facilities ........................................................ 164.3.3 Existing Environmental Management Issues .................................... 16

4.4 Benin Substation ........................................................ 174.4.1 Property Description ......................... ........................... 174.4.2 Existing Facilities .................................................... 184.4.3 Existing Environmental Management Issues .................................... 18

4.5 Alaoji Substation ....................................... 194.5.1 Property Description ....................................... 194.5.2 Existing Facilities ....................................... 194.5.3 Existing Environmental Management Issues .................................... 20

1/00/2204/EA/2204FinaIO20502.doc Golder Associates

February 2001 -ii- 003-2204

5.0 ENVIRONMENTAL IMPACTS OF APL-1 ACTIVITES ... 215.1 Conversion of Land ...................... ......................... 215.2 Noise Emissions from Transformers ................................ 22

5.2.1 Construction Noise ............................................... 225.3 Exposure of Personnel to PCB-Contaminated Soils ................................... 23

5.3.1 Background ............................................... 245.3.2 PCB Risk at the Oshogbo and Onitsha Substations ............................ 24

5.4 Lack of Environmental Management Planning ......................................... 25

6.0 ENVIRONMENTAL ACTION PLAN ............................................... 276.1 Supplementary Data Needs or Analysis ............................................... 27

6.1.1 Phase 1 Audit ............................................... 286.1.2 Phase 2 Audit ............................................... 28

6.2 Environmental Impact Mitigation .................................. 286.2.1 Noise Impacts ............................................... 286.2.2 Exposure to PCBs During Construction ......................................... 29

6.3 Environmental Management Planning ............................................... 296.3.1 Environmental Management Plan Summary .................... ................ 306.3.2 Institutional Arrangements and Strengthening .................................. 32

LIST OF TABLES

Table 1 Summary of Environmental Assessment FindingsTable 2 Summary of Environmental Action Plan Activities

LIST OF FIGURES

Figure 1 Map of Nigeria Showing NEPA Grid System Development Plan up toDecember 2005

LIST OF APPENDICES

Appendix A Environmental Policy Framework Evaluation ReportAppendix A-1 Resettlement Policy Framework Action Plan

Appendix B Summary Terms of Reference for Substation Phase 1 Enviromnental AuditAppendix B-1 Checklist for Phase 1 Environmental Audit of Substations

Appendix C Environmental Management Plan Outline

1/00/2204/EA/2204Fina1020502.doc Golder Associates

Executive Summary

February 2001 ES-1 003-2204

EXECUTIVE SUMMARY

This Environmental Assessment (EA) and Environmental Policy Framework Evaluation

(EPFE) have been prepared on behalf of the National Electric Power Authority of Nigeria

(NEPA) in support of project preparation for the Nigeria Power Transmission Project

(Project). The report addresses potential environmental impacts arising from proposed

project investments, supported by evaluations of Nigerian environmental and resettlement

policy frameworks.

Under the Project, funds will be used to add new 330-132 kV and/or 132-33 kV

transformers and associated facilities at five existing substations located at Oshogbo, Kano,

Onitsha, Benin, and Alaoji. Additional funds will be used for capacity building within the

newly formed NEPA Environment, Resettlement and Social Unit (ERSU).

The Project has been screened by the World Bank as requiring a Category B

Environmental Assessment (EA), leading to preparation of this EA report according to

World Bank guidelines. In support of potential future electric-sector investment activity, a

standalone Environmental Policy Framework Evaluation was also prepared, and has been

presented as Appendix A. The objective of the EPFE report is to evaluate the national

policy, regulatory, and institutional capacity for managing the generic suite of issues

associated with transmission line development.

The following potential issues associated with substation upgrade or rehabilitation were

examined.

* Impacts to biological resources arising from construction of newfacilities, including loss of habitats;

* Impacts to human resources arising from construction of new facilities,including economic displacement and involuntary resettlement;

* Noise related to construction and operation of large transformers;

IlOO/2204/EA12204Fin;dO20502.doc Gol der Associates

February 2001 ES-2 003-2204

* Public and workplace health and safety associated with past managementpractices at existing substations, including the use and disposal of PCBcontaining transformer oils;

* Contamination issues associated with ongoing management of facilitiesconstructed Project funding.

The Oshogbo, Kano, Onitsha, Benin, and Alaoji substations all have sufficient land within

existing fenced perimeters to accommodate the facilities proposed under the Project, and

no biological or social land use impacts are therefore anticipated as a result of project

activities.

The new transformer facilities will be located towards the center of the large

(approximately 30 hectare or larger) substation properties at all five sites. Continuous

noise levels, calculated using standardized equipment emission rates, will be on the order

of 46 dBA at the closest point to fenced property boundaries, which is comparable to the

45 dBA World Bank recommended standard for residential areas (nighttime), and well

within requirements for industrial areas. No residences or sensitive receptors were noted

in close proximity to the substation sites, so noise is not considered an issue for this

project.

No testing was performed to determine the presence or absence of polychlorinated

biphenyls (PCBs) in transmission cooling oils, oil-stained soils, or other media in the

five substations that were visited. Review of background literature and consultation with

manufacturers indicates that PCBs were phased out of manufacture and use in all countries

of the world at different dates during the 1970s and 1980s. For the purpose of

characterizing environmental risk in this report, equipment manufactured in a country prior

to enactment of such legislation is assumed to contain PCB-containing transformer fluids.

Using this criterion, it is a conclusion of this report that leakage and uncontrolled disposal

of PCB-containing these criteria cooling oils has occurred at the Oshogbo and Onitsha

facilities, but not at the Kano, Benin, or Alaoji substations. Given the persistence of PCB

1/OO/2204/EA/2204Final020502.doc Gol der Associates

February 2001 ES-3 003-2204

compounds in the environment, disturbance of contaminated soils during construction at

these sites presents a risk of PCB exposure to workers and substation personnel.

Mitigation measures proposed include the implementation of Phase I audits, including PCB

testing, at all five substations prior to construction design. If the presence of PCBs is

confirmed at a given substation during the Phase I investigation, a Phase II audit will then

be conducted to delineate the extent and concentration of contamination. The Phase II

audit results will allow development of construction plans for new facilities designed to

minimize disturbance of contaminated areas and therefore human exposure. Proposed

terms of reference and checklists for the Phase I audits are included as Appendix B.

Other issues encountered at the substations are related to an overall lack of environmental

management planning, with special regard to waste management and disposal. Proposed

mitigation actions include the development of site specific Environmental Management

Plans (EMP) as part of the Phase I audit scope. A summary table of contents for the EMP

is included as Appendix C.

Summary EA findings and proposed EMP activities are presented at the end of the text as

Tables 1 and 2, respectively.

As further described in the Environmental Policy Framework Evaluation (Attachment A),

Nigeria has a relatively mature environmental regulatory framework that requires

Environmental Impact Assessment (EIA) of all new projects. The type of EIA prepared is

determined on the basis of a project description submitted to the Federal Ministry of

Environment (FME formerly known as the Federal Environmental Protection Agency),

which uses the description for screening purposes. According to FME screening

guidelines, the substation renovations will likely be screened for a "CategoryII EIA,"

which is comparable to the World Bank CategoryB EA in its focus on environmental

management planning. It is therefore proposed that this report be submitted to FME for

comment and screening of the five substation renovation projects. Once Phase I audits are

1100/2204/EA/2204Final020502.doc Golder Associates

February 2001 ES-4 003-2204

complete, individual Category II EIA reports can be prepared under ESRU supervision for

submittal to FME.

1/00/2204/EA/2204FinaIO20X02.doc Golder Associates

February 2001 -1- 003-2204

1.0 INTRODUCTION AND OBJECTIVES OF THE ENVIRON-MENTAL ASSESSMENT

This Environmental Assessment (EA) and appended Environmental Policy Framework

Evaluation (EPFE) have been prepared on behalf of the National Electric Power Authority

of Nigeria (NEPA), in support of project preparation for the Nigeria Power Transmission

Development Project (Project). The EA has two broad objectives.

The first EA objective is to identify key environmental impacts that could arise from

implementation of activities under the proposed Project, as well as to propose appropriate

environmental management options for the elimination, reduction, or mitigation of those

impacts. As described in further detail in Section 3.0, the Project will support the

renovation or upgrade of a several existing transmission line substations and associated

support facilities. No greenfield substation construction is contemplated under this phase

of the project. It is the understanding of NEPA that, given the proposed scope of activities

and associated issues, the World Bank has screened the Project for a Category B EA. The

report has been prepared according to the guidelines presented in OP4.01 and supporting

policies for this type of EA, as well as those of the government of Nigeria, as further

described in subsequent sections. The EA report on Project activities constitutes the main

body of this report.

The second EA objective is to evaluate national capacity to identify, quantify, and manage

the generic suite of issues associated with power sector development in support of future

project activities. This evaluation has been approached as a form of sectoral environmental

assessment, the results of which are attached as the EPFE report (Appendix A).

The approach for preparing the Category B EA of the Project activities can be summarized

as follows:

* Summarize key aspects of the policy, legal, and administrativeframework of both the World Bank and the Government of Nigeria as

I/OO/2204/EAn2204FinaIO20502.doc Golder Associates

February 2001 -2- 003-2204

related to the management of environmental quality in the electrictransmission subsector (Section 2.0). This summary will defer to a moredetailed analysis contained in the attached EPFE report (Appendix A).

* Identify key activities and physical interventions of the Project(Section 3.0).

* Characterize existing environmental conditions at the sites of Projectactivities, including contamination issues originating from historicpractices (Section 4.0).

* Impacts arising from activities proposed under the Project (Section 5.0).

* Propose an Environmental Management Plan (EMP) that provides forthe acquisition of additional data needed for validating EA conclusions,mitigating impacts from the Project, and monitoring long-termenvironmental quality (Section 6.0).

I/00/2204/EA/2204FinaJO20502.doc Golder Associates

February 2001 -3- 003-2204

2.0 POLICY, LEGAL, AND ADMINISTRATIVE FRAMEWORK

The policy, legal, and administrative framework for environmental assessment for both the

government of Nigeria and the World Bank is the subject of detailed analysis in the

attached Environmental Policy Framework Evaluation (EPFE, Appendix A). Prepared as

a standalone deliverable in support of future investment activities in Nigeria's power

sector, the EPFE and the EA will be closely linked in any decision-making process

regarding environmental performance of the Project.

Given the level of detail in the EPFE, the corresponding Policy, Legal, and Administrative

Framework section of this EA will remain summary, referring to the former report's

detailed descriptions as needed.

2.1 Environmental Assessment in the Republic of Nigeria

Nigeria has relatively mature environmental regulatory framework that includes provisions

for environmental assessment, environmental audit, numerical environmental quality

standards, and enforcement.

Previously vested in a serious of sectoral policies and laws (e.g., the Forestry Law of 1978

and the Land Use Decree of 1978), responsibility for environmental quality in Nigeria was

consolidated under the authority of the Federal Ministry of Environment (FME). FME,

which was created under Decree No. 58 of 1988. Initially tasked with the development of

environmental quality standards for air, water, noise, and hazardous materials

management, FME was further authorized to request and review Environmental

Assessments of new projects, both public and private, under the provisions of Decree

No. 86 of 1992. Subsequent modifications to FME's authority also tasked the agency with

preparation of national policies on environmental protection, and environmental policy

inputs to the 5-year national development plans.

1/0012204/EA/2204Fina1O20502.doc Golder Associates

February 2001 -4- 003-2204

In addition to guidelines for EA preparation, Decree No. 86 also contains provisions for

the screening of projects according to impact potential, including an initial schedule of

activities for which mandatory EA preparation is required, and public disclosure of EA

findings. Subsequent procedural guideline publications by FME provide for screening

categories (1 to 3) that determine the type of EA report to be prepared, which in turn vary

in depth and scope of analysis as a function of project specific enviromnental risk. The

guidelines also call for environmental compliance monitoring as a follow-on activity to EA

review and approval. Classified as Infrastructure projects, electric generation and

transmission is an activity for which EA preparation is considered mandatory on all new

projects.

The national environmental legal and policy framework is the subject of a more detailed

description and comparative analysis in the Environmental Policy Framework Evaluation

report (Appendix A).

2.2 Environmental Assessment for World Bank Funded Projects

This section describes the Bank environmental assessment guidelines, standards, and

policies that may be applicable to the Nigerian Power Transmission Development Project.

As presented in the Bank's Operational Policy Note (OPN) 4.01, the information compiled

for an EA enables examination of a project's potential negative and positive environmental

impacts, comparison of these impacts with those of feasible alternatives, and

recommendation of measures needed to prevent, minimize, mitigate, or compensate for

adverse impacts and provide overall improvements in environmental quality. Additional

information on EA requirements of OPN 4.01 is presented in Appendix A.

2.2.1 World Bank Sectoral Guidelines

The World Bank views electric transmission lines as projects with a wide range of

environmental risk, depending on location and project size. As described in the

1/0oo204/EAn204Final020502.doc Gol der Associates

February 2001 -5- 003-2204

Environmental Assessment Sourcebook series (1990), impacts are principally associated

with the creation and maintenance of corridors, construction of the towers, and risk from

electromagnetic fields (EMF). Small-capacity lines of short length that do not pass

through sensitive areas may not require a comprehensive EA, though larger capacity,

longer lines will trigger preparation of an EA. For these reasons, transmission lines often

are ranked as a Category B project, meaning that full environmental assessment may not be

required, and that the depth of analysis called for in individual terms of reference can vary

according to anticipated impacts. Additional discussion of Bank sectoral guidelines is

presented in Appendix A.

2.2.2 World Bank Cross Sectoral Policies

The World Bank maintains the following cross-sectoral "safeguard" policies of relevance

to this project.

* Operational Policy (OP) 4.04 Natural Habitats;

* Operational Directive (OD) 4.30 Involuntary Resettlement (to beconverted to OD 4.30);

* OD 4.20 Indigenous Peoples;

* Operational Policy/Best Practice/Good Practice (OP/BP/GP) No. 11.03Management of Cultural Property in Bank-Financed Projects;

* OP 11.02 Wildlands.

Additional descriptive information on these policies is presented in Attachment A.

2.2.3 World Bank Numerical Standards

The Bank's Pollution Prevention and Abatement Handbook (1998; "Handbook') provides

detailed requirements for general and sector-specific control of pollution, including

1/0012204/EA/2204Fina1020502.doc Gol der Associates

February 2001 -6- 003-2204

numerical ambient, emission, and effluent standards for all major contaminants. The

Handbook presents standards on a sector basis, but the values are generally similar across

the sectoral lines. Of relevance to this project, the Handbook calls for a maximum sound

level of 45 and 55 A-weighted dB (nighttime and daytime periods, respectively) for

residential, educational, and institutional land uses, and 70 A-weighted dB for industrial

areas, measured at the property boundary.

I/O1/22041EA12204FinaIO20502.doc Gol der Associates

February 2001 -7- 003-2204

3.0 PROJECT DESCRIPTION

The Nigeria Transmission Development Project seeks to redress certain network

deficiencies and operational constraints of the Nigerian power transmission system.

Redressing network deficiencies will allow the efficient dispatch and transmission of the

additional expected power resulting from the emergency and longer term measures now

being taken to increase generation availability. The Project proposes an IDA loan

separated into an Investment component of US$ 55.44 million, a Technical Assistance

component of US$ 4.88 million, and a Social and Environmental component of

US$ 1.15 million.

3.1 Project Investment Component 1

Under this project investment component, $55.4 million dollars will be provided over the

period from 2001 through 2003 to support the following activities.

hmprovements at five main grid substations: Onitsha, Kano, Osogbo,Alaoji and Benin; and grid system reactive compensation;

: Installation of grid system metering at 132 kV to enable themeasurement of power supplied to unbundled distribution companies;

* Establishment of a new National Control Center (NCC) withSCADA/EMS facilities and associated communications requirements.

The first of these three subcomponent activities were the focus of attention during EA

development. The five main grid substations and proposed investment activities include

the following.

P Oshogbo Substation: This substation will be augmented by one150 MVA 330/132 kV transformer and associated 330 and 132 kVbays.

1/oon204/EAn2204Fina10205o2.doc Gol der Associates

February 2001 -8- 003-2204

* Kano Substation: This substation will be augmented by one 150 MVA330/132 kV transformer and associated 330 and 132 kV bays.

> Onitsha Substation: This substation will be augmented byone 150 MVA 330/132 kV transformer and associated 330 and 132 kVbays.

> Alaoji Substation: This substation will be augmented by one 150 MVA330/132 kV transformer and associated 330 and 132 kV bays.

* Benin Substation: This substation will be augmented bytwo 45/60 MVA 132/33 kV transformers and associated equipment.

Activities were at an initial, conceptual design level at the time of EA preparation, and no

technical information is available other than presented in this report. Descriptions of these

substations are presented in Section 4.0, based on observations made during

reconnaissance visits by the Golder-NEPA team.


Technical Assistance Components will provide support for the following activities

* Establishing the new transmission entity (TransysCo), including training,establishment of business plans and management structures, preparing anew grid code and providing engineering services.

> Developing transmission and system operation related secondaryregulations.

* Preparation for APL II and III projects, including institutionalstrengthening.


An Environment, Resettlement and Social Unit (ERSU)will be established at the outset of

project implementation. This unit will be transferred to the new TransysCo when it is

1/00/2204/EA/2204FinaiO20502.doc Golder Associates

February 2001 -9- 003-2204

established. Under this environment and social component, funds will be provided to

establish the ERSU and for staff training and capacity-building. Once established, the

ERSU will have responsibility for monitoring and evaluation of Project environment and

social activities, and for preparing, with the assistance of consultants when necessary, EIA

and EMPs, and Resettlement assessments and action plans for subsequent phases of the

APL. Apart from the project related work, ERSU will cover the whole TransysCo. The

scope of ERSU's work under the Project also includes designing and supervising the

Phase 1 environmental audits to determine the need for remediation actions if past waste

disposal methods are found to have resulted in PCB contamination of soil at the

substations.

1/00122041EA12204FinaIO20502.doc Golder Associates

February 2001 -10- 003-2204

4.0 DESCRIPTION OF THE AFFECTED ENVIRONMENT

Transmission line substations are found throughout Nigeria, occurring in all of the major

climate and life zones of the country. However, the five substations slated for Project

investment activities are located in urban/industrial areas. None of the proposed substation

renovation projects will entail expansion of an existing substation fenced perimeter

conversion of land to new use. At the time of EA preparation, the substations slated for

investment activity consisted of the following sites.

4.1 Oshogbo Substation

The Oshogbo Substation was visited by members of the NEPA-Golder environmental

assessment team on November 16, 2000. This facility is located in Osun State, Western

Highlands geographic region, and was constructed in 1968 on land adjoining the National

Control Center, just west of the city of Oshogbo. Originally covered with dry deciduous

forest, Osun State is now almost entirely converted to agriculture and urban areas.

4.1.1 Property Description

The substation property is enclosed by a 2-meter high fence of concrete block construction,

providing controlled access. No site plans of the property or any equipment were available

at the time of the reconnaissance visit. Site surface area was visually estimated to be

around 30 hectares, of which more than one-half was unoccupied. Areas in active use

were topped with coarse gravel. Land surrounding the substation is unoccupied, and

covered with a low, dense growth of secondary vegetation. No residences or agricultural

activities were observed within the immediate vicinity of the substation boundary.

1/00/2204/EA12204Final020502.doc Gol der Associates

February 2001 -11- 003-2204

4.1.2 Existing Facilities

The facilities at the Oshogbo station included the following key components.

* A single 150 MVA 330-132 kV ASGEN (Italian) transformermanufactured in 1968;

* A single 150 MVA 330-132 kV Mitsubishi (Japanese) transformermanufactured in 1974 (Photo 1);

* A shunt reactor (ASGEN) manufactured in 1968 (Photo 1);

* Circuit breakers and switches associated with 6 incoming 330 kV linesand 8 outgoing 132 lines;

* Control room, offices and maintenance shops;

* Salvage yard for used equipment and materials.

4.1.3 Existing Environmental Management Issues

Interview of site management staff was conducted during the site reconnaissance. Though

the property and equipment appeared orderly and well maintained, management staff

indicated that no formal environmental management is currently practiced at the Oshogbo

station.

As related to substation environmental issues (i.e., other than employee health and safety),

the historic impacts generated by the lack of formal environmental management planning

are principally related to waste generation and disposal. No records are maintained related

to the disposal of wastes, principally spent oil from circuit breakers, and used equipment is

stored onsite in a designated salvage yard (Photo 4). Estimates of waste transformer oil

generated were on the order of four drums (55 US gallon) per year, all originating with the

replacement of carbonized circuit breaker oil. All replacement oils are mineral

(i.e., non-PCB) as further evidenced by labels of empty drums stored onsite. Transformer

1/00/2204/EA/2204Final020502.doc Golder Associates

February 2001 -12- 003-2204

cooling oils are not subject to high voltage arcing and carbonization, and are periodically

reconditioned in situ to lower moisture content. Transformers and the shunt reactor were

reportedly filled at commissioning, and no replacement oil is added. As such, the

transformers do not generate significant waste streams of used oil during normal course of

operations (i.e., tap changers and circuit breakers mounted on the transformer may

contribute to the estimated four barrels annually). Spent oil is reportedly used for weed

control within the property boundary, and empty drums are stored onsite (Photo 5).

Heavy surface staining was observed around the base of shunt reactor at Oshogbo,

extending approximately 10 meters from the base of the structure. According to

management staff, the oil spillage occurred over a period of several years due to a fracture

in the reactor's cooling oil containment vessel, which was finally repaired in 1991.

Estimates of the total quantity of lost transformer oil were on the magnitude of 200 barrels.

A used ASGEN 150 MVA transformer was observed in the scrap yard, of identical make

as the one in active service Photo 4. This equipment was reportedly decommissioned in

1974, and replaced with the Mitsubishi reactor currently in service. The transformer was

likely drained of cooling oil prior to it's movement to the existing site, and no information

was available on the fate of the 13,450 gallons (imperial = 52,455 liters, or 953 drums)

originally contained in the cooling circuit, per information on the data plate.

The use of PCBs in cooling oils was phased out in Japan by decree in 1972 (Bruce

Congalton, Mitsubishi Electric Power Products Inc., personal communication), and the

equipment used onsite was originally filled with mineral oil. However, similar Italian

legislation was passed in 1988 (DPR 216/88), well after the manufacture date of the

ASGEN equipment. The ASGEN company no longer manufactures transformers, and

representatives could not be reached for comment.

1/00/2204/EA/2204FinalO20502.doc Gol der Associates

February 2001 -13- 003-2204

4.2 Kano Substation

The Kano Substation is located in Kano State of the North Central Highlands geographic

region. Originally characterized by arid savannah vegetation, the majority of Kano State

has long been converted to dryland cultivation of millet and maize or pasturelands.


The approximately 30-hectare area occupied by the Kano Substation is located on the

northwest edge of the city of Kano, state capital, second largest city in the country and the

site of extensive commercial and manufacturing development. The substation was

constructed in 1977 on property now enclosed by a 2-meter high fence of concrete block

construction, providing controlled access. No site plans of the property or any equipment

schematic layouts were available at the time of the reconnaissance visit. Site surface area

was visually estimated to be the same as the Oshogbo station (i.e., around 30 hectares), of

which more than one-half is unoccupied and cleared of vegetation (Photo 7). Areas in

active use were topped with coarse gravel.

Land immediately surrounding the substation (i.e., within 100 meters) is unoccupied,

though villages are clustered in fairly high density along the access road. No agricultural

activity was observed within the immediate vicinity of the substation boundary.

The areas containing the transformers and circuit breakers areas are located towards the

property center, at least 150 meters from the closest point of the perimeter wall.

1/00/22041EA/2204Fina1020502.doc Golder Associates

February 2001 -14- 003-2204


The facilities at the Kano Substation include the following key components.

* Two 150 MVA 330-132 kV Mitsubishi transformers, manufactured in1977 (Photo 6);

* A Mitsubishi shunt reactor manufactured in 1977 (Photo 6);

* Circuit breakers and switches associated with 2 incoming 330 kV linesand 6 outgoing 132 lines;

* A trailer-mounted 132-33 substation;

' Control room, offices and maintenance shops.

4.2.3 Existing Environmental Mpaena ent Issues

Interview of the substation Assistant General Manager and the maintenance manager was

conducted during the site reconnaissance. The property and equipment generally appear to

be well maintained. As with other substations visited, the management staff indicated that

no formal environmental management is currently practiced.

As related to substation environmental issues (i.e., other than employee health and safety,

not addressed in this report), the historic impacts generated by the lack of formal

environmental management planning are principally related to waste generation and

disposal. No records are maintained related to the disposal of wastes, principally spent oil

from circuit breakers, estimated at 40 to 50 drums per year. Carbonized transformer oil is

used to control weeds on the property, which is the disposal method for the entire volume

generated. Perhaps due to good maintenance, or the relatively young age of the station,

used equipment consisted only of one spent circuit breaker and a replacement tap changer

for one of the 150 MVA transformers.

1/00/2204/EA/2204Final020502.doc Gol der Associates

February 2001 -15- 003-2204

As described in Section 4.1.3, PCB-containing compounds were phased out in Japan

beginning in 1972, and the type of equipment used in the Kano substation was designed to

use mineral oil (Bruce Congalton, Mitsubishi Electric Power Products Inc., personal

communication). Pending confirmation testing during the Phase I audits recommended

prior to construction (see Section 6.1), the presence of PCBs on site is therefore regarded

as highly unlikely.

4.3 Onitsha Substation

The Onitsha substation is located in Anambra State, within the Eastern Scarplands

Geographic Region. Originally covered with the Guinea Savannah vegetation community,

the region has largely been cleared for agriculture or human settlement, as is the case with

most of the Nigerian national territory.


Constructed in 1968 the Onitsha substation is located in an area of relatively dense urban

development of the city of Onitsha. As with other substations of similar capacity, the

approximate surface area is 30 hectares, enclosed by a 2-meter high cinderblock wall that

provides controlled access. The working portion (approximately one-half) of the

substation property is topped with coarse gravel, and the rest occupied by a low cover of

weedy vegetation. Land use immediately outside the perimeter wall is residential.

Operational components of the facility (i.e., transformers and associated equipment) are

located towards the center of the property, with a distance estimated at 150 meters to the

nearest point on the perimeter wall.

A system of concrete gutters collects surface water runoff from the active areas of the

substation for open discharge offsite.

I/00/2204/EA/2204Fina1020502.doc Gol der Associates

February 2001 -16- 003-2204


The facilities at the Kano Substation include the following key components.

* One 90 MVA 330-132 kV ASGEN transformer, manufactured in 1968;

* One 90 MVA 330-132 kV Mitsubishi transformers, manufactured in1975;

* (shunt reactor);

* One 60 MVA 132-33 kV Hyundai transformer, manufactured in 1982;

* One 60 MVA 132-33 kV Mitsubishi transformer, manufactured in 1978;

* One 60 MVA 132-33 kV Trafo-Union transformer, manufactured in1973;

* Circuit breakers and switches associated with incoming 330 kV lines andoutgoing 132 kV lines;

* Control room, offices and maintenance shops;

* Used equipment scrap yard.


Consistent with the other two substations, the primary existing environmental issue arises

from historic and ongoing lack of environmental management of the site. No plan exists

for the disposal of domestic or process wastes, which are again largely comprised of

transformer oils, presumably in the same volumes as the Oshogbo and Kano facilities

(40 to 50 drums per year from routine maintenance). In keeping with maintenance

practices on other substations, transformer cooling oil is reconditioned in situ, contributing

little to the waste stream, except in the case of catastrophic spillage or disposal of an entire

load of oil upon transformer decommissioning. Some oily surface staining was observed,

though not as heavy as in the case of the Oshogbo Substation.

1/00'2204/EA/2204FinalO20502.cdoc Golder Associates

February 2001 -17- 003-2204

A used ASGEN 150 MVA transformer was observed in the scrap yard, of identical make

to the one observed at the Oshogbo facility. This equipment was reportedly

decommissioned in 1975, and replaced with the Mitsubishi reactor currently in service.

The transformer was likely drained of cooling oil prior to it's movement to the existing

site, and no information was available on the fate of the 13,450 gallons

(imperial = 52,455 liters, or 953 drums) originally contained in the cooling circuit.

For reasons provided in Section 4.1.3, it must be presumed that the ASGEN equipment

was originally commissioned using PCB-containing cooling oil that was still present upon

decommissioning. Though no staining was observed of the magnitude found at Oshogbo,

no records were kept to document the fate of the oil contained in the decommissioned

transformer, as well as of those quantities generated through routine maintenance of the

ASGEN equipment. It may be presumed that spilled oil was left on the surface, and other

quantities disposed of either through weed control or hauling offsite.

4.4 Benin Substation

The 330/132/33 kV Benin Substation is located in Edo state in the Eastern Scarplands

Geographic Region. Originally covered with Guinea Savannah vegetation community, the

region has largely been cleared for agriculture or human settlement, as is the case with the

other substations, and indeed most of the Nigerian national territory.


Located on Sapele Road in the central part of Benin City, this boundary fence of this

facility is surrounded by urban development. As with the other substations, the Benin

facility is fenced and access is controlled. The majority of the approximately 30-hectare

property is topped with gravel, with a sparse cover of weedy vegetation elsewhere.

I/00/2204/EA/2204FinalO20502.doc Golder Associates

February 2001 -18- 003-2204

Existing transformer and switch equipment is located towards the center of the site, with

no human habitation or activity on the unoccupied sections.


Existing equipment at the Benin substation includes the following key components.

* One 150 MVA 330-132 kV Mitsubishi transformer, manufactured in1977;

* One 60 MVA 132/33 kV Mitsubishi transformer, manufactured in 1977;

K One 60 MVA 132/33 kV Mitsubishi transformer, manufactured in 1996;

One 45 MVA 132/33 kV Mitsubishi transformer, manufactured in 1982;

* One 30 MVA 132/33 kV Mitsubishi transformer, manufactured in 1986;

* Circuit breakers and switches associated with incoming 330 andoutgoing 132 or 33 kV transmission lines;

* Control room, offices and maintenance shops.

In addition to active equipment, various spent components and used oil drums were

scattered about the site.


Unlike the Onitsha and Oshogbo facilities, all equipment at the Benin station, including

spent or discarded gear, post-dates the use of PCB-containing cooling oils, and no PCB

contamination issues are believed to exist. As is the common practice with other

substations visited by the NEPA-ERSU team, there appears to be no environmental

management planning for the site. Used transformer oils are disposed of on-site, often as

weed control, and areas of heavy surface staining were noticeable. Spent equipment,

1/oo/2204/EA/2204Fina1020502.doc Gol der Associates

February 2001 -19- 003-2204

empty drums and other solid waste is apparently abandoned in situ, with no organized

storage or long-term plan for disposal. Runoff is collected in a series of shallow surface

channels, where it is directed into offsite drainage features. No material use or waste

disposal records are kept onsite, and no estimated volumes were available for major waste

streams.

4.5 Alaoji Substation

The 330/132 kV Alaoji substation, located on the outskirts of the Alaoji Aba township.


The Alaoji substation property is by appearance larger than the other fourbeing proposed

for Project funding (no property measurements were available). Active equipment

occupies approximately one-third of the site, on the graveled one-half of the property. The

entire property is enclosed by fence, with controlled access and no existing land use on the

non-active portions. No groundwater wells were observed in the immediate vicinity of the

substation property, which contains a scattering of residences and other structures.


The Alaoji substation has the following key components.

* Two 330-132 kV transformers oflSO MVA capacity, manufactured byMitsubishi in 1978;

* Circuit breakers associated with incoming 330 and outgoing 132 kVtransmission lines;

* Control rooms, maintenance buildings and offices.

The grounds are relatively free of used equipment and solid wastes.

ItOO/2204/EA/22t4FinaIO20502.doc Golder Associates

February 2001 -20- 003-2204


The two 150 MVA transformers were manufactured after the legislated phase out date for

PCB compounds in Japan, such that this form of contamination is likely not an issue. As

with other substation facilities examined during the EA field visits, no environmental

management planning is practiced at the facility, and waste streams are neither quantified,

tracked or disposed of in a systematic manner. Less evidence of oil spillage could be

observed at this site as compared to the other four facilities planned for investment under

the Project activity.

[/00/2204/EAa22O4FinaIO20502.doc Golder Associates

February 2001 -21- 003-2204

5.0 ENVIRONMENTAL IMPACTS OF APL-1 ACTIVITES

Potential issues that may be generically associated with the construction and operation of

new substation facilities of the capacity proposed under the Project are summarized below.

> Conversion of land to accommodate equipment needed for expandedcapacity, with impacts arising potentially arising from loss of naturalhabitat and involuntary/economic displacement of residents;

* Noise emissions from transformers;

' Exposure of personnel to hazardous wastes, including PCBs, duringconstruction-related disturbance of contaminated soils;

> Future contamination of soil and water from inadequate waste disposal,resulting from environmental management planning.

A description of each facility is provided above, and potential environmental issues are

summarized below as well as in Table 1.

5.1 Conversion of Land

All new installed transformer capacity proposed under the Project will take place within

existing property boundaries of the five substations that were visited. Land use within

these properties has been dedicated for substation purposes for periods from 34 to

43 years, and is fenced so as to allow controlled access. Approximately one-third to

one-half of the 30+ hectare surface area of all substations is now occupied by active

equipment. Each substation manager was interviewed during site reconnaissance visits

regarding potential expansion areas, and sufficient land to accommodate the equipment

described in Section 3.0 could be readily identified in each case. Vegetation control is

practiced on land within site boundaries presently unoccupied by active equipment, and no

human use or transit of those sites occurs.

[/00/22041EA12204Fina1020502.dmc Golder Associates

February 2001 -22- 003-2204

In conclusion, there will be no impacts to existing ecological or socio-economic land uses

caused by land use conversion arising from activities proposed under the APL-1 phase of

the Project.

5.2 Noise Emissions from Transformers

5.2.1 Construction Noise

Construction noise will originate during the operation of heavy equipment used for earth

leveling and transportation, including bulldozers, excavators and cement mixers, which

have acoustic power levels of 90 to 130 dBA. Construction noise levels are typically

intermittent and temporary in duration.

Operational noise from substations can be emitted by equipment operation and circulating

cooling water. Equipment in the substation that creates audible noise includes cooling air

fans, main transformer cooling fans, and main transformer oil circulation.

Ambient sound level measurements were not made during the reconnaissance visits.

However, the substations are located on the fringes of major urban developments, and

ambient noise observed during visits was restricted to the existing emissions from

transformers.

As described in Attachment A, the GON has standards governing maximum ambient noise

that provide maximum sound levels that range from 90 A-weighted dB for an 8-hour

exposure to 115 A-weighted dB for 15-minute exposures. The World Bank guidelines call

for a maximum sound level of 45 and 55 A-weighted dB (nighttime and daytime periods,

respectively) for residential, educational and institutional land uses, and 70A-weighted dB

for industrial areas. These sound levels are to be measured at the property boundary to

determine guideline compliance

l/00/2204/EAM2204Final020502.doc Golder Associates

February 2001 -23- 003-2204

The following analysis was conducted to evaluate potential noise issues arising from

construction and operation of the new 150 MVA 330-132 kV transformer facilities at the

five substation sites.

Sound levels generated by electrical transformers are a function of its power rating, in

MVA, and are described in the Edison Electric Institute's (EEI) "Electric Power Plant

Environmental Noise Guide," which was the reference used in this analysis. The

algorithms provided in the EEI document were applied for 0 to the largest transformer size

of those found at the five substations, the 150 MVA transformers at the Kano facility. The

sound power level for this equipment, on a continuous basis, is calculated to be 94dB.

The sound power level for the 60 MVA transformers at the same substation is calculated to

be 92 A-weighted dB.

Using the EEI sound power levels for the two 150 MVA and three 60 MVA transformers

at the Kano Substation and the wave divergence propagation routine (i.e., sound levels

generated by a source decreases as a function of distance), the overall predicted sound

level impacts to the nearest property boundary (minimum 200 meters) would be

approximately 46 A-weighted dB. This predicted sound level impact does not take into

account any additional path-specific sound-attenuating benefits, such as vegetative cover,

shrubs, etc. Given this fact, the operational impacts of the new transformers at all of the

five substations proposed for Project investment will most likely comply with the World

Bank noise guidelines for residential, educational, and institutional land uses.

5.3 Exposure of Personnel to PCB-Contaminated Soils

As described in Section 4.0, there is a very high likelihood that PCB-contaminated soils

are present on the Oshogbo and Onitsha sites. Though no field analysis was conducted

during the reconnaissance visits to confirm the presence of PCBs, the ASGEN equipment

was manufactured and commissioned well over a decade prior to these compounds being

phased out in Italy, the country of origin. Furthermore, an extensive spill of transformer

I/oo/2204/EA12204Fima]020502.doc Golder Associates

February 2001 -24- 003-2204

oil from the shunt reactor at Oshogbo was observed, the fate of nearly 1,000barrels of oil

from the decommissioned ASGEN transformers at Oshogbo and Onitsha is not

documented, and historic practice has been to dispose of used oils by land application for

weed control.

5.3.1 Background

Not manufactured in any country since 1977, PCBs (i.e., there are over 200isomers and

compounds) were widely used in a number of industrial applications up until that year.

Because of their insulating properties, chemical stability and relative inflammability, they

have been found to be particularly useful as coolants, where the standard concentration in

transformer oil was 500 ppm.

T-he compounds are known to cause chronic reproductive effects, gastric disorders and skin

lesions in laboratory animals, which is the basis of their having been listed by the USEPA

as a probable human carcinogen. The compounds are further suspected of being

environmental estrogens (i.e., mimicking the effects of the natural hormone estrogen on

the body)'. For these reasons, the compounds have been phased out for all industrial uses

worldwide, and are subject to remediation and treatment as hazardous waste under the

regulatory frameworks of most industrialized countries.

5.3.2 PCB Risk at the Oshogbo and Onitsha Substations

PCB compounds are highly water insoluble, a property that also results in adsorption to

organic materials in sediments and soils. PCBs are also highly persistent in the

environment, with a half-life of several years in soils2. Though water insoluble, PCBs can

be mobilized in soils if light organic solvents (e.g., gasoline, degreasers and cleaners) are

'Agency for Toxic Substances and Disease Registry, September 1997. ToxFAQs CAS#1336-36-32 PCB Risk Assessment Review Guidance Document. January 2000. Versar Inc. 6850 Versar Center,Springfield, Virginia 22151,

1/00/2204/EA/2204FinalO20502.doc Golder Associates

February 2001 -25- 003-2204

spilled on the contaminated sites, which could reach groundwater bearing a load of

solubilized PCBs.

If land applied within the property boundary, either for weed control or convenient

disposal, the PCBs from waste oil at the Onitsha and Oshogbo substations will still be

present in the near-surface soils in high concentration. Bulldozing, leveling, and other

disturbance of contaminated soils during construction of new facilities may result in

exposure of workers, or nearby residents via skin contact, inhalation of PCBs adsorbed to

organic material in dust particles, and transport by surface runoff of construction site

sediments.

Finally, decommissioned equipment and materials at the substation sites, including

breakers, transformers and empty drums, are potentially hazardous if PCB compounds

were ever in use during active life. Exposure from these sources would depend entirely on

how the materials were disposed of. No plan exists at the present time for further action

with any of these materials.

The presence or absence of PCBs is readily determined in the field using test kits. These

kits contain reactive compounds, and are not allowed upon commercial aircraft, making

their importation to a country like Nigeria difficult. However, importation can be

arranged within the time frame of project implementation, and their use will be an integral

part of Phase I site audits recommended as part of pre-construction activity (Section 6.0).

5.4 Lack of Environmental Management Planning

Aside from the issue of PCBs, the waste management practices at all five substations

present an ongoing environmental issue. Though lacking the toxicity of PCBs, transformer

mineral oil is nonetheless a potential pollutant, and the absence of appropriate disposal

techniques could lead to additional contamination from maintenance of transformers

acquired under the Project. The absence of disposal guidelines for smaller amounts of

1/00/22041EAn14Fim1020502.doc Gol der Associates

February 2001 -26- 003-2204

waste generated through equipment and vehicle maintenance likewise constitutes an

environmental issue that will increase as substation capacity is expanded. Measures for

addressing these issues are also presented in Section 6.0.

I/00/22N4/EA/2204FinalO20502.doc Golder Associates

February 2001 -27- 003-2204

6.0 ENVIRONMENTAL ACTION PLAN

The basic components of the Environmental Action Plan (EAP) are as follows.

* Supplementary Data Needs or Analysis;

* Impact Mitigation;

* Site Environnemental Management Planning;

* Institutional Arrangements and Strengthening.

Each of these components is addressed in the following sections, and is summarized in

Table 2. Costs of EAP actions are presented as part of the Environmental Policy

Framework Evaluation report (Appendix A).

6.1 Supplementary Data Needs or Analysis

This component addresses any data or analysis needed to validate the key conclusions of

the EA, but which were either not practical at the time of EA preparation, or critical for

reaching a decision about the project's potential impacts or the feasibility of their

mitigation. In the case of the Project, the primary post-EA data collection and analysis

consists of environmental audits, to be performed on each facility during the development

of construction engineering plans. These audits will validate the presence or absence of

historical contamination issues that may need to be addressed prior to final construction

design. The audit terms of reference will also call for will also call for the preparation of

site-specific environmental management plans to address ongoing environmental issues as

well as monitoring.

I/00/2204/EA/2204Fina1020502.doc Gol der Associates

February 2001 -28- 003-2204

6.1.1 Phase I Audit

The initial round of audits will be Phase 1, consisting principally of site inspections, record

review, and interviews, to be conducted according to ASTM standards by a qualified

environmental consulting firm. A checklist of potential issues will be prepared using the

findings of the Project EA, supplemented by standard sectoral checklists. A summary

outline of environmental audit guidelines is presented as Table 3. Comprehensive Phase I

environmental audit guidelines and a checklist for substations are presented in Appendix C,

and will be used for preparing Phase I bid documents. For budgeting purposes, it is

assumed that all substations will be the subject of Phase 1 audit activities.

6.1.2 Phase 2 Audit

It is anticipated that the results of the Phase 1 audits will indicate that some sites require

further investigation and characterization, to be implemented through a Phase 2 audit

process. The product of the Phase 2 audit will be a site-specific plan that will include

approaches to minimize risks arising from disturbance of contaminated soils during

construction of new facilities under the Project. For budgeting purposes, it is assumed a

Phase 2 analysis will be needed at the Oshogbo and Onitsha substation sites due to the

likely presence of PCB-contaminated soils on the property.

6.2 Environmental Impact Mitigation

6.2.1 Noise Impacts

Construction activities will be limited to daylight hours so as to minimize impacts on any

residential areas.

I/oo/2204/EA12204Final020S02.doc Golder Associates

February 2001 -29- 003-2204

6.2.2 Exposure to PCBs During Construction

A final construction plan will be developed based upon results from the Phases I and II

audits, if it is determined that PCBs are present in a concentration sufficient to pose risk to

onsite or offsite human health. Elements of exposure minimization that may be included

are summarized below.

* Delineation of the extent and concentration of soil contamination, andestablishing the new construction footprint to avoid disturbance of thoseareas;

> Water application for dust suppression during grading and excavation;

S Sediment and erosion control measures to prevent runoff ofunconsolidated, contaminated soils;

- Respiratory and skin protection;

* Removal of contaminated soils.

Removal of contaminated soils to an offsite location is predicated on the existence of a

proper disposal facility. PCBs are tolerant of very high temperatures, and if incompletely

combusted will produce dioxin-contaminated emissions, a problem even more serious than

the original. Identification of waste disposal facilities will take place during construction

management planning.

6.3 Enviromnental Management Planning

The environmental impacts associated with the lack of standard operating procedures

would be best addressed by establishing a systematic EMP for each of the substations.

EMPs identify activities with potential environmental impacts, describe methods to

mitigate and monitor those impacts, identify persons responsible for implementing the

elements of the plan and appropriate training for those individuals, and prescribe a

1/00/2204/EA/2204Fina1020502.doc Gol der Associates

February 2001 -30- 003-2204

schedule and cost estimate for implementation. For example, specific activities which

could be included in the EMPs are implementing a waste management program for the

transformer maintenance operations.

An outline for an EMP is provided in Appendix C; the elements of the EMP are

summarized below.

6.3.1 Environmental Management Plan Summary

This summary of an EMP is based on draft World Bank guidance published in May 1996

(World Bank BP 4.01 Annex C). It is important to note that the following elements must

be applied to each identified potential impact.

Mitigation

The EMP will identify and summarize all anticipated significant adverse environmental

impacts from site activities, including socioeconomic impacts. For the electric sector

facilities, these issues include, at a minimum, air emissions, fuel and oil handling, solid

and hazardous waste management, and wastewater management. Mitigation measures to

minimize environmental impacts should be identified. The mitigation measures should be

related to the type of impact to which it relates, and the conditions under which it is

required (i.e., continuous, periodic, or in the event of contingencies). Designs, equipment

descriptions, and operating procedures should be specified.

Monitoring

Environmental monitoring of affected media must be performed to measure the

environmental impacts of the site activities and the effectiveness of the mitigation

measures. The EMP should provide a description of the monitoring measures, including

parameters to be monitored, methods to be used, sampling locations, frequency of

[100/2204[EA/2204FinaO20502.doc GoIder Associates

February 2001 -31- 003-2204

measurements, detection limits, and thresholds for corrective action. Monitoring and

reporting procedures should be identified to ensure early detection of conditions that

necessitate corrective actions, and provide information on the progress and results of

mitigation.

For the Nigerian power sector, environmental media to be monitored include air,

wastewater, surface water, and groundwater. Parameters monitored should be appropriate

for the media and source. For example, long-term air monitoring is necessary for the

power parks, periodic personal air monitoring for worker health and safety purposes may

be appropriate for the operations centers, and air monitoring is likely not necessary for the

substations. Similarly, petroleum hydrocarbons and volatile organic compounds are

appropriate parameters to be monitored in stormwater discharges from all facilities.

For each environmental media, ambient conditions should be established to the extent

feasible. Given the number of other potential sources for environmental contamination of

these media, it is likely not possible to determine "unimpacted' conditions. Accordingly,

monitoring points at the upwind, upstream, or upgradient portion of the property boundary

are likely necessary to determine media quality at the point of entry to the site. Similarly,

point of compliance monitoring locations must be established to determine media quality at

the point of exit from the facility. Given the variability of media flow direction

(e.g., wind direction), multiple entry and exit monitoring points are likely necessary. A

comparison of data from the entry and exit points will establish the net impact from the

site.

Monitoring locations are also likely required at specific discharge sources, such as

wastewater outfalls and power plant stacks. Depending upon the environmental media,

off-site monitoring locations may be necessary to measure impacts distant from the facility.

For example, air monitoring locations may be required several kilometers from a power

park stack.

I/0204/EA/2204FinaIO20502.doc Golder Associates

February 2001 -32- 003-2204

6.3.2 Institutional Arrangements and Strengthening

As referenced in Section 3.3, NEPA environmental management capability will be greatly

strengthened with the creation of the Environmental and Social Review Unit (ESRU).

NEPA's traditional focus has been on the management of impacts arising from involuntary

resettlement associated with hydropower development, and little institutional capability or

experience exists with EIA, audit, and compliance. With Project support, the ERSU will

be strengthened so as to manage environmental issues of an expanded transmission sub-

sector.

Though the organization of the ERSU is still underway, it will likely have administrative

divisions responsible for EIA of new projects, management and compliance of existing

projects, as well as resettlement planning functions.

A number of activities will be implemented with Project support to strengthen individual

professional capabilities for managing power sector environmental issues, as summarized

below.

- Environmental Impact Assessment (EIA) training, to enable ESRU staffto prepare TORs for bid and oversee preparation and agency approval ofEIA on sectoral projects;

* Environmental Management Plan (EMP) training, to enable ESRU staffto work with NEPA facility managers in the preparation andimplementation of site specific environmental management activities;

* Environmental audit training, to enable ESRU staff to prepare TORs forbid, oversee implementation of and interpret results of audits relatedongoing compliance of NEPA facilities;

* ESRU staff study tours to visit Transmission sub-sector environmentalmanagement agencies in other countries;

* Development of a geographical information system (GIS) capability inorder to organize and apply data of relevance to environmental issues inthe transmission subsector.

1/00/2204/EA/2204Fina1020502.doc Golder Associates

February 2001 -33- 003-2204

Training in environmental assessment, environmental management planning, and

environmental audit will be an early Project priority, since the ERSU staff will be

responsible for oversight of the substation audits, development of appropriate mitigation

activities, and support of individual project EIA with FME.

Further description and costs of institutional strengthening activities are presented in

Appendix A.

1/0012204/EA/2204FinaWO20502.doc Golder Associates

Tables

TABLES

February 2001 Golder Associates 003-22041!Xli2204!EA,'2204Fi,ali(20502 dos

TABLE 1

SUIMMARY OF ENVIRONMENTAL ASSESSMENT FINDINGS

i.sue Ar-WActfwt v lZ .rojed: RP0.1.Q . .U4 Bl, ,.. * .o I OB. ... W S CUni at.,

Oshogbo Substation 330kV/132kv I new 150 Sufficient space within existing cleared, No human habitation within the existing, Oil staining of surface soils throughoutOshogbo, Osun State MVA/330-132 graveled and fenced confines of the fenced confines, or in close proximity to facility, likely associated with

2 x 150 MVA kV substation yard. Yard surface drains the perimeter. Facility is on the edge of replacement of breaker oilTransformers Transformer & lead to nearby dry ravines. No observed a major urban area, with ready supply of

associated groundwater wells. labor for construction. Signs of more recent oil staining (veryfacilities heavy) near the reactor, associated with

No impacts to surface or groundwater No impacts from either resettlement, loss leaks in the cooling oil containmentresources anticipated if proper mitigation of land access or induced development compartments as much as 200 barrels)measures introduced during construction. are anticipated.

Transformer/reactor manufacture dateNo impacts to biological resources (1968) prior to final phase-out date ofanticipated PCBs in country of origin (1982 )

Used transformer on-site, empty ofcooling oil. No record of oil disposal.Manufacture (1968) also predates phase-out of PCBs in country of origin (1968)

No designated offsite disposal of used oilor equipment.

No site-specific environmentalmanagement plan

Kano Substation 330kV/132kv I new 150 kV (Ibid) (Ibid) Few signs of heavy oil staining, thoughKano, Kano State 2 x 150 MVA Transformer & spent transformer oil (breakers) used for

Transformers associated vegetation controlfacilities

Transformer/reactor manufacture date(1977) post-dates time of PCB phase outin country of origin (1972)

No designated offsite disposal of used oilor equipment.

No site-specific environmental________________________ ______________ management plan

February 2001 Golder Associates 003-22041/00/2204/EA/2204FinaIO20502.doc

Oriitsha Substation 330kV132kv 1 new 150 (Ibid) (Tbid) Transformer/reactor mnfcuedateOnitsha, Anambra State 2 x 150 MVA MVA (1968) prior to fnal phase-out date of

Transformers Transformer & PCBs in country of origin (1982)associatedfacilities Used transformer on-site, empty of

cooling oil. No record of oil disposal.Manufacture (1968) also predates phase-out of PCBs in country of origin (1968)

No designated offsite disposal of used oilor equipment

No site-specific environmentalmanagement plan

Benin Substation 330/132/33 kV I new 150 (lbid) (Ibid) Transformer manufacture date (1n977)Benin City, Edo State MVA after funa phase-out of PCBs in country

I x 150 MVA Transformer of origin (1972)Transformer and associated

facilities No designated offsite disposal of used oil2 x 60 MVA or equipmentTransformers

No site-specific environmentalI x 45 MVA management planTransformer

I x 30 MVATransformer

Alaoji Substation 330/132 kV 2 new 45/60 (Ibid) (Ibid) Transformer manufacture date (1977)Alauji Aba MVA 132/33 after final phase-out of PCBs in country

2 x 150 MVA kV of origin (1972)Transformers Transformers

and associated No designated offsite disposal of used oilfacilities or equipment

No site-specific environmentalI_management plan

February 2001 Golder Associates 003-2204I/OOn2204/EA/2204FinalO20502.doc

TABLE 2

SUMMARY OF ENVIRONMENTAL ACTION PLAN ACTIVITIES

Supplementary Data and Analysis Contamintion of substation site with Phase I audit to address or determine the Osogbo, Kano Onitsha, Benin and Alaojitransformer oils potentially contamiing PCBs, following:and exposure during construction under theproject * Presence of PCBs in

existing transformercooling oil

* Presence of PCBs in oil-contaminated soils

* Location of possiblereceptor points (wells,surface water users etc)not observed during EAreconnaissance

Issue/Impact Mitigation Lack of site-based environmental management Phase I environmental audit scope to include Osogbo, Kano, Onitsha, Benin and Alaojiplan providing inter alia guidelines for waste preparation of draft site environmentalmanagement/ disposal management plans (EMP)

Issue/Impact Mitigation Potential need for contamination remediation Phase II enviromnental audit to delineate (Budget provision for 2)if presence of PCBs is encountered extent of contamination and prepare terms of

reference for remediation actions

Site remediation activities as determined byPhase 11 results

Environmental Performance Monitoring Lack of on-going compliance auditing and Phase I environmental audit scope to include Osogbo, Kano,Onitsha, Benin and Alaojireporting preparation of draft site EMPs to include

_______________________________________ ~~~~~compliance audit procedures for each facilityInstitutional Arrangements and Strengthening (see Attachment A) .

February 2001 Golder Associates 003-2204l/012204IEAJ22o4FinaJO205O2.doc

FIGURES

February 2001 Golder Associates1/00122041EA/2204FialO20502. doc

Figures

APPENDIX A

ENVIRONMENTAL POLICY FRAMEWORKEVALUATION REPORT

February 2001 Golder Associates1 /00/2 204/EA /2204 F inaIO20502 doc

MAP OF NIGERIA SHOWING NEPA GRID SYSTEM DEVELOPMENT PLAN UP TO

DECEMBER 2005 t o0

JOC.AVAN YO 7

ATLANTIC OCEANCOTL1

,ADAMAWAj

0~~~~~~~~~~~

ATANA OCEN J -"Eu

Rg~~~~~~~~~~~~ a~~~~~

Appendix A

APPENDIX A

ENVIRONMENTAL POLICY FRAMEWORKEVALUATION REPORT

February 2001 Golder AssociatesIl/OO2204/ EA12204Final020502. doc

APPENDIX AFebruary 2001 -i- 003-2204

TABLE OF CONTENTS

1.0 INTRODUCTION AND OBJECTIVES ........................................................ 1

2.0 DESCRIPTION OF PROPOSED ACTIVITIES UNDER APL-2 .......................... 3

3.0 POTENTIAL ENVIRONMENTAL ISSUES ASSOCIATED WITH APL-2 ............ 5

4.0 ENVIRONMENTAL POLICY, LEGAL, AND REGULATORY FRAMEWORKFOR NIGERIA AND THE WORLD BANK . . ............................................... 6

4.1 Environmental Policy and Regulatory Framework for Nigeria ........................ 64.1.1 Creation of the Federal Ministry of Environment .......... ..................... 64.1.2 Environmental Impact Assessment .......................... 7

4.1.2.1 Project Screening and Scoping ................. ............................. 74.1.2.2 EIA Content .................................................................... 9

4.1.2.3 EIA Submittal and Review ................................................... 94.1.3 Supporting Regulatory and Policy Framework . . 10

4.1.3.1 Numeric Environmental Standards ............. .......................... 104.1.3.2 Public Health and Safety ........................ ........................... 104.1.3.3 Impacts Due to Land Conversion: Natural Resources ....... ........ 114.1.3.4 Impacts to Human Resources .............................................. 114.1.3.5 Public Disclosure during EIA ................. ............................ 124.1.3.6 Post-Commissioning Environmental Audit and Compliance

Monitoring ................................................................ 144.1.3.7 Public Grievance Procedures .............................................. 14

4.1.4 Institutional Capacity for Environmental Management ........ ............. .. 154.2 World Bank Environmental Policies and Guidelines .... 15

4.2.1 Sectoral Guidelines ................................................................ 174.2.2 Cross Sectoral Guidelines .......................................................... 17

4.2.2.1 OP 4.04 Natural Habitats ..................... ............................. 184.2.2.2 OD 4.30 Involuntary Resettlement (to be converted to OD 4.30).. 184.2.2.3 OD 4.20 Indigenous Peoples ................. ............................. 184.2.2.4 Operational Management of Cultural Property in Bank-Financed

Projects ................................................................ 194.2.2.5 OP 11.02 Wildlands ......................................................... 194.2.2.6 Biodiversity ................................................................ 21

5.0 CONCLUSIONS AND PROPOSED ACTIONS: NIGERIAN ENVIRONMENTALPOLICY FRAMEWORK ................................................................. 23

5.1 Environmental Assessment ................................................................. 235.2 Numeric Standards . ................................................................ 235.3 Protection of Wildland Habitats ........................................................... 23

I/C0/2204/EA/2204Fina1AppA02050 1. doc Golder Associates

APPENDIX AFebruary 2001 -ii- 003-2204

5.4 Public Consultation ........................................... 245.5 Involuntary Resettlement ....................................... 255.6 Cultural Property ........................................................ 255.7 Compliance Auditing and Environmental Management Planning . . 26

5.8.1 Professional Capacity: Training Activities ............... ....................... 275.8.2 ERSU Organization and Administrative Responsibilities ..................... 28

6.0 PROPOSED COST AND TIMELINE FOR STRENGTHENING ACTIVITIES ..... 31

LIST OF TABLES

Table A-1 Report Contents Comparison (FME and OPN 4.01) and Policy ActionTable A-2 Implementation Costs and Timing of Environmental Management Plan

LIST OF FIGURES

Figure A-I Schematic of the Nigerian EIA Screening, Scoping, Preparation, andReview Process

I/0012204/EA12204FinalAppAO2050i .doc Gol der Associates

APPENDIX AFebruary 2001 -1- 003-2204

1.0 INTRODUCTION AND OBJECTIVES

Golder Associates Inc. has prepared this Environmental Policy Framework Review (EPFR)

of the Nigeria Power Transmission Project (Project) on behalf of, and in collaboration with

professional staff of the Nigerian Electric Power Authority (NEPA). The report is

intended to address potential environmental issues associated with future investment

activities under any subsequent project phases not yet scheduled for implementation; as

well as any private sector investment enabled by the proposed restructuring and

rehabilitation of the transmission subsector under the Project. Specific environmental

impacts, mitigation and monitoring measures associated with these future projects will be

identified through the national environmental assessment process, with oversight from the

newly formed Environment, Resettlement and Social Unit of NEPA.

The purpose of this EPFR is therefore to assure that the government of Nigeria and NEPA

have, or will develop, the requisite legal and institutional capability to address

environmental issues, including preparation of Environmental Assessments, arising from

future investment activities planned by the project. This EPFR report was based on

interview of key Government of Nigeria (GON) and NEPA staff, as well as review of

environmental legislation and policies.

The EPFR report has the following objectives and organization.

* Summary of the types of future investment projects (Section 2.0), aswell as environmental and social issues associated with theirimplementation (Section 3.0);

> Preparation of a summary comparison of World Bank and Nigerianenvironmental laws, policies, and standards (Section 4.0), withparticular emphasis on the latter's provisions for environmentalassessment and associated activities such as public participation andenvironmental management planning;

* Recommendations on policy and institutional strengthening actions asneeded to address issues (Section 5.0);

1/00/2204/EA/2204Fina]AppAO2050I .doc Gal der Associates


* Estimated costs and timing for all policy and institutional strengtheningactions, including training, provision of equipment and materials, andfunding (Section 6.0).

It should be noted that national policy and capacity regarding involuntary resettlement, the

key issue most often associated with transmission lines, has been the subject of an

evaluation and report prepared under separate terms of reference (Appendix B).

Conclusions and key recommendations from the resettlement policy assessment are

incorporated into the findings of this EPFE report.

1/00/2204/EA/2204Fina]AppAO20501 Ad Gol der Associates


2.0 DESCRIPTION OF POTENTIAL FUTURE INVESTMENTACTIVITIES

The Project purpose is to improve Nigeria's electric power sector performance,

specifically in the transmission sub-sector. The following investment activities will be

undertaken during the current Project.

* Removal of existing constraints to power transmission by rehabilitationand upgrade of existing systems;

* Facilitating the development of a new transmission company, byenabling private participation in existing and expanded transmission;

* Development of regulations specific to the operation of a restructuredtransmission sub-sector.

At the time of EPFR preparation, the following activities are envisioned as potential future

investment activities.

: Optical fibre project: Phase II;

- New SCADA/EMS system for NCC (Oshogbo);

' Alaoji - Umahia 132kV D.C. line (125 kIn);

* Umahia 132kV substation;

* Benin - Onitsha second 330kV line (137km);

* Alaoji - Enugu 330kV S.C. line (175 kin);

* Enugu 330kV Substation (expansion);

* Onitsha - Nnewi 132kV line (25 km);

* Nnewi 132kV Substation;

* Makurdi - Yandev - Wukari 132 kv S.C. line (184 kim);

1/00/2204/EAI2204FinalAppAO20501.doc Golder Associates


* Yandev 132kV Substation;

* Wukari 132kV Substation.

If fully implemented, this investment list would entail 312 km of 330 kV capacity and

276 km of 132 kV capacity transmission line. It is not known at this time if these new

lines could be co-located along existing transmission line rights of way, or if new corridors

must be identified. This uncertainty is the rationale for this assessment of GON

institutional capacity for conducting environmental assessments of new transmission line

projects.

110012204/EA/2204FinalAppAO2050 1. doc Golder Associates


3.0 POTENTIAL ENVIRONMENTAL ISSUES ASSOCIATED WITHFUTURE INVESTMENT ACTIVITIES

A generic suite of issues is associated with the development of new transmission lines, as

described below.

* Impacts to human populations located in future transmission line rightsof way. These impacts may include (i) the involuntary restriction ofaccess to legally designated parks and protected areas results in adverseimpacts on the livelihood of the displaced persons; or (ii) the involuntarytaking of land and other assets resulting in:

* relocation or loss of shelter; or

- loss of assets or access to assets; or

* loss of income sources or means of livelihood, whether or not theaffected persons must move to another location.

* Potential public safety issues arising either from the innate hazard ofhigh-voltage lines, exposure to electromagnetic field (EMF) radiation, oraircraft collisions;

* Potential direct conversion of natural habitats for use as transmission linecorridors and rights-of-way;

* Increased access to vulnerable natural areas as a result of transmissionline and access road construction and maintenance (i.e., induceddevelopment);

* Potential exposure of human populations to EMF radiation;

* Noise generation by substation transformer equipment.

I1/00/204/EAI2204FinalAppAO20501.doc Golder Associates


4.0 ENVIRONMENTAL POLICY, LEGAL, AND REGULATORYFRAMEWORK FOR NIGERIA AND THE WORLD BANK

This section presents summary descriptions and comparison of both the Government of

Nigeria and World Bank environmental policies and guidelines.

4.1 Environmental Policy and Regulatory Framework for Nigeria

Nigeria has a mature environmental regulatory framework relative to other countries on the

African continent, and which includes provisions for environmental assessment,

environmental audit, numerical environmental quality standards and enforcement.

4. 1. 1 Creation of the Federal Ministry of Environment

Previously vested in a serious of sectoral policies and laws (e.g., the Forestry Law of 1978

and the Land Use Decree of 1978), responsibility for environmental quality in Nigeria was

consolidated under the authority of the Federal Environmental Protection Agency (FEPA),

which was created under Decree No. 58 of 1988, under the supervision of the Federal

Environmental Protection Council (Council). Subsequently reorganized as the Federal

Ministry of Environment (FME), the agency's initial mandate included the following.

* Establish Federal water quality standards and effluent limitations;

* Protect air and atmospheric quality;

* Protect the ozone layer;

* Control the discharge of hazardous substances;

* Enforce the process, including power to search, seize and arrest as wellas procedures in respect of suits against the agency.

1/00/2204/EA/2204FinialAppAO2050 1.doc Gol der Associates


In 1992, the Decree No. 58 was further amended (Decree No. 86) to task FME with the

preparation of a comprehensive National Policy for protection of the environment, of

which the centerpiece strategy was development of procedures for environmental impact

assessment of all development projects.

4.1.2 Environmental Impact Assessment

In addition to guidelines for EA preparation, Decree No. 86 also contains provisions for

the screening of projects according to impact potential, including listed activities for which

mandatory EA preparation is required, as well as provisions for public disclosure of EA

findings for follow-on monitoring.

4.1.2.1 Project Screening and Scoping

A Procedural Guideline document (FEPA 1995a) has been published to guide project

screening and scoping. In consideration of criteria that include impact magnitude, extent,

duration, risks, significance and availability of mitigation measures, the screening process

leads to one of three categories, as described below.

0 Category I projects will require a full Environmental Impact Assessment(EIA);

* Category II projects may require only a "partial: EIA, which will focuson mitigation and environmental planning measures, unless the project islocated near an "Environmentally Sensitive Area" (ESA), in which casefull EIA is required;

> Category III projects are considered to have "essentially beneficialimpacts" on the environment, for which an Environmental ImpactStatement (EIS) will be prepared by FME.

The procedural guidelines provide examples for the term "ESA" that closely approximate

World Bank criteria for areas of special concern, and include the following.

1/00/2204/EA/2204FinalAppAO2050 1.doc Golder Associates


* Coral reefs;

* Mangrove forests;

* Small islands;

* Tropical rainforests;

* Areas with erosion-prone soils;

* Areas prone to desertification;

* Natural conservation areas;

* Wetlands of national or international importance;

* Areas which harbor threatened or endangered species;

* Areas of particular scientific interest;

* Areas of historic or archeological interest;

* Areas of importance to threatened ethnic groups.

Screening takes place on the basis of a "Project Proposal" document that consists of a

description of the activity to be undertaken, a summary outline of potentially affected

elements in the surrounding environment, and proposed impact reduction or mitigation

measures incorporated by project design.

Finally, the Procedural Guidelines also provide a list of activities subject a priori to

Category I, II, and III EIA, again strongly based on similar guidelines in World Bank

Sourcebook and Operational Policy literature. In the Nigerian guidelines, "Power

Generation and Transmission" is listed as a Category I activity only for thermal projects of

10 MW or greater, combined cycle thermal generation, nuclear generation or

hydro-electric generation for dams and reservoirs of a certain size or above. The

Category II activities include "small scale electric transmission" without criteria as to

determination of scale.

I/OO/2204/EA/2204FinalAppAO2050i .doc Golder Associates


4.1.2.2 EIA Content

A series of sectoral ELA guidelines (FEPA 1995b) have also been published that are

derived from USEPA and World Bank documents. The Infrastructure Sectoral Guidelines

address electric power generation and transmission, identifying issues typically associated

with transmission line projects including the following

* Impacts arising from land acquisition and development, includingimpacts to human and biological resources;

* Visual/aesthetic impacts, noise and vibration;

* Diseases arising as a function of development induced by constructionaccess and service road access.

An "EIA Report Writing Format" section is included in both the Procedural and Sectoral

guidelines that presents a recommended report organization that includes all of the topic

areas covered by the World Bank OPN 4.01. A comparison of report contents from the

FME format and from OPN 4.01 is presented in Table A-1.

4.1.2.3 EIA Submittal and Review

The Procedural Guidelines summarize the process of EIA preparation and submittal to the

FEPA Secretariat, which conducts the screening, assigns an EIA category and manages the

scoping process (Figure 1). If determination is made that an EIA is required, a review

panel is appointed under criteria received from the Federal Environmental Protection

Council. This panel manages the sufficiency evaluation of the EIA and is also responsible

for public disclosure (see Section 4.2.4). Once approved, a technical committee is named

to write the government's Environmental Impact Statement (EIS), which will include

provisions for monitoring during construction and operation.

1/00/2204IEAI2204FinalAppAO2050I .doc Golder Associates


4.1.3 Supporting Regulatory and Policy Framework

The Nigerian enviromnental assessment process is supported by regulations containing

numeric standards for ambient environmental quality, as well as to control pollutants in

emissions and effluents.

4.1.3.1 Numeric Environmental Standards

Development of numeric standards for measuring ambient environmental quality and

regulating contaminant discharge of effluents and emissions was the initial mandate of

FEPA, predating the creation of EIA and audit procedures enabling their enforcement.

Key legislation titles are listed below.

* S.I. 8 National Environmental Protection (Effluent Limitation)Regulations 1991 requires permitting of any industrial discharge intopublic air or waters, subject to standards described in S.I. 9.

* S.I. 9 National Environmental Protection (Pollution Abatement inIndustries and Facilities Generating Wastes) Regulations 1991 providessector-based numerical standards for effluent and emission quality(except for noise).

* Guidelines and standards for Environmental Pollution Control inNigeria - Federal Ministry of Environment (FME) 1991, which includeambient noise standards.

Additional regulations address the land-conversion and human health issues associated with

transmission line projects, as described below.

4.1.3.2 Public Health and Safety

Public health and safety is addressed by NEPA guidelines establishing 7.5 m and 15 m,

respectively, as the Minimum Horizontal Distance (MHD) between a building and NEPA

high-tension overhead wires of 11 and 33 kvA, respectively. Note that MHD refers to the

/OO12204/EA/2204FinalAppA02050 1.doc Gol der Associates


distance measured from the centerline on the ground (i.e., the point directly beneath the

conductor). An MHD for lines of 132 and 330 kvA has been established as 30 m and

60 m, respectively.

Public health and safety is further addressed by the Civil Aviation Act of 1990, which

prohibits the construction of transmission lines along and around airports.

4.1.3.3 Impacts Due to Land Conversion: Natural Resources

The Mineral Resources Act of 1990 requires that transmission line corridors not be

established through "Minerals and Natural Resource Areas," thereby protecting their

economic value.

Impacts to biological resources is provided only by the prohibition of transmission line

construction through areas formally designated as Wild Animal Preservation areas or

Lakes and National Parks, as contained in the Wild Animal Preservation Act of 1990. No

policy guidelines were found that address the conversion of non-protected lands of high

biological diversity or habitat value (i.e., "Wildlands" in World Bank policies).

4.1.3.4 Impacts to Human Resources

Virtually no regulatory or policy reference to socio-economic impacts of power

transmission projects is integrated into the environmental regulatory framework of Nigeria.

All issues related to involuntary resettlement or compensation for loss from the state

exercise of eminent domain are addressed in the Land Use Act of 1978 (amended 1990).

Issues arising from loss of property and involuntary resettlement have been addressed

under a separate set of TORs for preparation of a Resettlement Action Plan Policy

Framework. The objective of this exercise was to evaluate existing GON policies and

practices, and recommend actions needed to align them with World Bank requirements as

1100122041EA/2204FinalAppAO2050I .doc Golder Associates


provided in OD 4.30. The entire report is provided as Attachment C, with key fmdings

summarized below.

* The NEPA Property and Resettlement Departments have considerablehistoric experience with indemnification and resettlement arising fromhydropower projects, such as the as Jebba Hydro Project(12,000 resettlers) and Shiroro Hydro Project (19,000 resettlers). Theseactivities were the subject of the following comments in the ResettlementAction Plan Policy Framework report.

> In the case of property losses cash settlements have been provided, butno alternative land made available to displaced parties as required underOD 4.30.

* Cash settlements on civil structures were not always based on fullreplacement cost, again as required by OD 4.30.

- Cash settlements for loss of croplands was not always based on marketvalues for produce, or full replacement costs for long-term assets such asfruit or forestry species, whereas OD 4.30 requires restoration of fullincome streams in cases of economic displacement.

Recommended policy actions are summarized in Section 5.5, and described in detail in

Attachment B.

4.1.3.5 Public Disclosure During EIA

Decree No. 86 (1992) contains numerous references to public disclosure, including the

following statement of objectives in the opening clause.

The objectives of any environmental impact assessment shall be toencourage the development of procedures for information exchange,notification and consultation between organs and persons when proposedactivities are likely to have significant environmental effects on boundary ortrans-state or on the environment of bordering towns and villages"(Section 1. [c]).

1/00/2204/EA/2204FinalAppAO205O0 .doc Gol der Associates


However no specific guidance is provided on how public consultation is to be carried out,

with Section 9. [4] stating the following.

The Council may determine an appropriate method in which the decision ofthe Agency shall be published so as to reach interested persons or groups,in particular the originators or persons interested in the activity subject ofthe decision.

Considerable guidance is provided in the closing portion of Decree No. 86 on the

establishment of public files containing EIA and EIS documentation, and on assuring that

the public maintains access to those files.

Guidance for public disclosure other than that found in Decree No. 86 is scant. The

Procedural Guidelines refer to a public review process, to be conducted during EIA

sufficiency evaluation. Reference is made to the requirement that "venues of display will

include, among others, the LGA (i.e., local government authority), state EPA and FEPA

headquarters and that... the public shall be invited to participate in this review process

through newspaper advertisements."

In practice, the public is invited (by radio as well as newspaper announcement) to

participate in FEPA EIA review meetings, and signed meeting minutes are accepted as

evidence of "stakeholder consultation" (Philomena Adinye, Assistant Director of EA

Division, FEPA; personal communication).

In summary, the public consultation process consists of an open-door policy for

stakeholder participation in agency meetings regarding sufficiency of EIA reports, and

assuring public access to those reports as well as to FEPA's statement of findings (i.e., the

EIS). No written or verbal description was encountered to village/community-level

meetings conducted for the sole purpose of obtaining stakeholder input.

100/2204/EA/2204FinalAppAO2050l.doc Golder Associates


4.1.3.6 Post-Commissioning Environmental Audit and Compliance Monitoring

As is often the case in developing economies, the FEPA staff has been challenged to

enforce monitoring and compliance measures provided for in the environmental

management plan of the EIA, due to factors that include policy/guideline weakness and

institutional capacity.

The scope of Decree No. 86 virtually ends with the EIA process, providing no guidance on

assuring environmental performance after projects are approved. Both the Procedural and

Sectoral Guideline documents make nominal references to compliance auditing, but again

provide no guidelines for its implementation.

Interview of FEPA personnel further indicated little familiarity with environmental

auditing and that regular compliance reporting did not occur; as was confirmed by

interview of substation management personnel. Likewise interview of private sector

contractors who prepared EIA reports revealed almost no familiarity with environmental

audit practice.

4.1.3.7 Public Grievance Procedures

No reference has been found in the policy or regulatory literature to a formal mechanism

for handling grievances related to environmental issues. Interview of FEPA personnel

indicates that formal grievance statements may be submitted to the FEPA Legal Unit, who

is then tasked with developing the agency's response. Anecdotal information also indicates

that public pressure has lead to government response on some occasions, usually when

issues are of sufficiently high profile to gain attention at the national level.

The NGO community also reportedly serves a public watchdog function on environmental

issues. Interview of the Nigerian Environmental Society (NES) personnel indicated some

history of public advocacy on environmental issues. In one instance, the NES developed a

memorandum to advise all government agencies, donors and national NGO groups that

I/0012204/EA/2204Fi nal AppAO2050 1. doc Golder Associates


construction was underway on the National Stadium project without an EIA having been

prepared, obligating the government to prepare one (Ane Leslie Adogame, Executive

Secretary, Nigerian Environmental Society, personal communication).

4.1.4 Institutional Capacity for Environmental Management

Under the terms of reference for the Power Transmission Development Project, NEPA

will create an Environment, Resettlement and Social Unit (ERSU). The ERSU will have

the broad mandate of assuring that new activities implemented in the transmission

subsector with Project funding comply with both the national and World Bank policies

regarding environmental and social impact.

It is expected that the ERSU will be largely drawn from the staff of NEPA's resettlement

and property departments, which are the organizations that have been responsible for

addressing involuntary resettlement and related compensation activities in the past.

Though not fully designed or established, the proposed ERSU organization will include

resettlement and environmental sections, each with distinctive responsibilities.

No formal institutional capability assessment was performed on NEPA staff. However, it

is apparent that, while possessing excellent empirical skills, particularly in the planning

disciplines, most NEPA staff members have not received sufficient training and exposure

to environmental management tools such as EA, environmental management planning or

environmental audit. Proposed capacity-building actions are presented in Section 5.0.

4.2 World Bank Environmental Policies and Guidelines

The Bank's policy requirement for the evaluation of potential environmental impacts of all

lending projects is described in OP/BP/GP 4.01 Enviromnental Assessment (EA). As

stated in OP/BP/GP 4.01, environmental consequences should be recognized early in the

project cycle and taken into account in project selection, siting, planning, and design by

1/00/2204/EA/2204FinalAppAO2050 1.doc Golder Associates


preventing, minimizing, mitigating, or compensating for adverse environmental impacts

and enhancing positive impacts.

The OP/BP/GP 4.01 also presents guidelines for screening projects into one of the

three EA categories A, B, or C, depending on the anticipated risk of adverse impact. With

regard to screening, the World Bank views electric transmission lines as projects with a

wide range of environmental risk, depending on location and project size. As described in

the Environmental Assessment Sourcebook series (1990), impacts are principally

associated with the creation and maintenance of corridors, construction of the towers, and

risk from electromagnetic fields (EMF). Small-capacity lines of short length that do not

pass through sensitive areas may not require a comprehensive EA, though larger capacity,

longer lines will trigger preparation of an EA. For these reasons, transmission lines often

are ranked as a Category B project, meaning that full environmental assessment may not be

required, and that the depth of analysis called for in individual terms of reference can vary

according to anticipated impacts.

Supplementary guidance on EA preparation for the World Bank of relevance is provided in

the following series of publications.

:- Environmental Screening. Environmental Sourcebook Update No. 2.April 1993

* Sectoral Environmental Assessment. Environmental Sourcebook UpdateNo. 4. October 1993

* Public Involvement in Environmental Assessment: Requirements,Opportunities and Issues. Environmental Sourcebook Update No. 5.October 1993

> Privatization and Environmental Assessment: Issues and Approaches.Environmental Sourcebook Update No. 6. March 1994.

> Environmental Auditing. Environmental Sourcebook Update No. 11.August 1995.

IC00/2204/EA/2204FinalAppAO2050I .doc Golder Associates


* Environmental Performance Monitoring and Supervision.Environmental Sourcebook Update No. 14. June 1996.

* Challenges of Managing the EA Process. Environmental SourcebookUpdate No. 16. December 1996.

* Analysis of Alternatives in Environmental Assessment. EnvironmentalSourcebook Update No. 17. December 1996.

* Health Aspects of Environmental Assessment. EnvironmentalSourcebook Update No. 18. July 1997.

* Environmental Management Plans. Environmental Sourcebook UpdateNo. 25. January 1999.

4.2.1 Sectoral Guidelines

Sectoral guidelines for electric power transmission systems are stated in the Technical

Paper No. 154, Environmental Assessment Sourcebook, Volume III, Guidelines for

Environmental Assessment of Energy and Industry Projects (1991), "Sourcebook III. " The

guidelines state that electric power transmission lines will affect natural and sociocultural

resources. The special issues associated with transmission systems are effects on land use,

health and safety hazards and induced development. Negative impacts to land resources

such as fragmentation of habitat and vegetation along the right of way or introduction of

new access to protected areas (i.e., wildlands) can result. Increase risk of electrocutions

can occur due to placement of low-slung lines near human activity. Electromagnetic fields

created by the transmission line can result in potential health hazards. Induced

development or population relocation may occur in or on the borders of a right-of -way.

4.2.2 Cross Sectoral Guidelines

The Bank also maintains policies to address key issues on a non-sectoral basis (also known

as "safeguard policies"), of which the following are relevant to the suite of issues that

could arise from the Project.

I/00/2204/EA/2204FinalAppAO2050 1.doc Golder Associates


4.2.2.1 OP 4.04 Natural Habitats

The Bank does not support projects involving the significant conversion of natural habitats

unless there are no feasible alternatives for the project, and its siting and comprehensive

analysis demonstrate that overall benefits from the project substantially outweigh the

environmental costs. If the EA indicates that a project significantly convert or degrade

natural habitats, the project includes mitigation measures acceptable to the Bank. The

Environmental Assessment Sourcebook Update No. 20 (October 1997) provides related

guidance on the topic area of managing biological diversity as an EA issue area.

4.2.2.2 OD 4.30 Involuntary Resettlement (to be converted to OD 4.30)

Involuntary resettlement as used in this policy covers both (a) the involuntary displacement

(physical and non-physical) of affected people that arises from change in land use or water

use, loss of productive assets or loss of income or means of livelihood, whether or not the

people must move to another location, and (b) the measures for mitigating the impacts of

displacement. The policy applies whether or not the Bank itself is financing part of the

project that may require involuntary resettlement, and it covers resettlement resulting from

activities that are not part of the Bank-financed project but are necessary to achieving the

objectives of the project. Displaced persons are assisted in their efforts to improve their

former production levels, income-carrying capacity, and living standards, or at least

restore them to the levels they would have without the project.

4.2.2.3 OD 4.20 Indigenous Peoples

This directive provides guidance to ensure that indigenous people benefit from

development projects, and to avoid or mitigate adverse effects of Bank-financed

development projects on indigenous peoples. Addressing issues pertaining to indigenous

peoples must be based on the informed participation of the indigenous people themselves.

1100/2204/EA/2204FinalAppAO20501.doc Gol der Associates


4.2.2.4 Operational Management of Cultural Property in Bank-Financed Projects

Policy Note (to be issued as OP/ BP/GP 4.11) No. 11.03

Bank policy is to assist in the preservation of cultural property where part of a

Bank-financed operation, and to avoid its elimination. The Bank normally declines to

finance projects that will significantly damage nonreplicable cultural property, and assists

only those projects that are sited or designed so as to prevent such damage. The

Environmental Sourcebook Update No. 8 (September 1994) also provides additional

guidance on the management of impacts to cultural property during EA preparation.

4.2.2.5 OP 11.02 Wildlands

The World Bank policies and guidelines on wildlands, defined as land and water areas

virtually unmodified by human activity, are presented in Operational Policy Notes 11.02

Wildlands: Their Protection and Management in Economic Development (World Bank,

1986). The Bank policy is to avoid the elimination of wildlands and to actively assist in

their preservation. Certain wildlands, including protected areas, are deemed to be of

"special concern." The Bank normally declines to finance projects involving conversion of

wildlands of "special concern," even if such conversion occurred prior to the Bank being

invited to consider financing. Wildlands of special concern are areas that are recognized to

be exceptionally important in conserving biological diversity or perpetuating environmental

services, and can be classified into two types. First, are wildlands officially designated as

protected areas by governments, sometimes in collaboration with the United Nations or the

international scientific community. Designated protected areas may be National Parks and

protected areas, Biosphere Reserves, World Heritage Natural Sites, Wetlands of

International Importance (i.e., Ramsar designation), areas designated for protected status

in national conservation strategies or master plans, and similar "wildlands management

areas" (WMAs; i.e., areas where wildlands are protected and managed to retain a

relatively unmodified state; Annex 1 of OPN 11.02).

1/0012204/EA/2204FinalAppAO2050 1.doc Golder Associates


A second category is wildiands that are as yet unprotected by legislation, but recognized by

the national and/or international scientific and conservation communities, often in

collaboration with the United Nations, as exceptionally endangered ecosystems, known

sites of rare or endangered species, or important wildlife breeding, feeding, or staging

areas. These include certain types of wildlands that are threatened throughout much of the

world, yet are biologically unique, ecologically fragile, or of special importance for local

people and environmental services. Wildlands of special concern often occur in tropical

forests, Mediterranean type brushlands, mangrove swamps, coastal marshes, estuaries, sea

grass beds, coral reefs, small oceanic islands, and certain tropical freshwater lakes and

riverine areas. Wildlands of special concern also occur in certain geographical regions

(Annex 2 of OPN 11.02) that have been reduced to comparatively small patches and

continue to undergo rapid attrition. As a result, these regions harbor some of the most

threatened species in the world.

When wildlands other than those of special concern may become involved, the Bank

prefers to site projects on lands already converted (e.g., logged over, abandoned,

degraded, or already cultivated areas) sometime in the past, rather than in anticipation of a

Bank project. Deviations from this policy must be explicitly justified.

As defined in Operational Directive 4.01, Annex D, Wildlands: Their Protection and

Management, wetlands are defined as wildlands of special concern. In the Bank's

Operational Policy Notes (OPN) 11.02 Wildlands: Their Protection and Management in

Economic Development (World Bank, 1986), wetlands are identified as a subset of

wildlands of special concern. Therefore, the policies and guidelines for wildiands, as

summarized above, apply to wetlands as well. The Bank also recognizes the significance

of small or unrecognized wetlands and the need for those areas to be considered during

preparation of the project.

1/00/2204/EA/2204FinalAppAO20501 .doc Golder Associates


Wetlands are valuable ecosystems that provide wintering, breeding, and feeding areas for

waterfowl, shorebirds, and other species of birds. The areas also provide spawning and

feeding areas, as well as year-round habitat for fish and other wildlife. In addition to

serving ecological functions, wetlands serve as water storage areas and natural filtering

areas that improve water quality.

Wildlands and wetlands of worldwide importance have been identified via the RAMSAR

process. Named after the Iranian town in which the first convention was held, RAMSAR

is accepted shorthand for the "International Convention of Wetlands of Global

Importance." The World Bank cannot support actions that propose degradation to areas

protected under this agreement, or actions that violate any other international community.

4.2.2.6 Biodiversity

The Bank upholds two policies on biodiversity, as presented in Environmental

Sourcebook I (World Bank 1991), as well as subsequent updates. The Bank supports the

preservation of endangered species and critical habitats, and the conservation and

management of wildlands. The Operational Manual (World Bank 1984) Statement 2.36

Environmental Aspects of Bank Work states that the Bank will not finance projects that

"cause severe or irreversible environmental degradation" nor projects that "would

significantly modify natural areas" identified by international organizations as biologically

valuable or by governments as protected areas.

Bank guidelines pertaining to biodiversity identify actions to take in the very early stages

of an environmental assessment. During the early part of the environmental assessment

preparation stage, an environmental reconnaissance can be performed to identify and assess

the significance of impacts to biodiversity and identify any other concerns. Sourcebook I

suggests that assessors identify specific ecosystems the project will affect, the important

biological features of the identified ecosystems, the general nature of the project's impacts,

1OO/2204/EA/22O4FinalAppAO2050 .doc Gol der Associates


and the significance of impacts relative to ecosystem types in the region and/or country,

and the cumulative effects and trends for the ecosystem types.

Sourcebook I presents several possible technical actions that could be incorporated in

mitigation plans, such as establishing equivalent conservation units elsewhere in the region

to offset unavoidable loss of habitat in the project area (mirroring policies for impacts to

wildlands, wetlands and tropical forests). Several institutional actions are also presented,

such as the strengthening of existing agencies with management responsibility for parks

and preserves, other wildlands management areas, and biological resources in general.

The Bank recognizes the importance of community involvement in the successful

maintenance of biodiversity in the future, and highlights the need to maintain

communication among affected groups, develop an awareness of the importance and

benefits of maintaining biodiversity, awareness of the apparent costs and benefits of the

project, knowledge of realistic management options, and recognition of local customs,

traditions, and cultural values.

For the purpose of identifying threatened and endangered (T/E) species, the IUCN Red

Databook series should be used to complement national (if any) lists. Operating through

the World Conservation Monitoring Center in Glan, Switzerland, the IUCN has established

a website where country-specific searches may be conducted.

Measures for ensuring that projects adequately address World Bank policies on

environmental and social soundness issues are incorporated into several Bank documents.

In addition to ODs, several policy papers reflect World Bank policies on environmental

and social soundness issues. These include the World Bank Environmental Guidelines

(World Bank 1988a), the Environmental Assessment Sourcebook Series (Word Bank

1991), updates to the sourcebook series dated from 1993 to 1996, The World Bank

Participation Sourcebook (World Bank 1996) and the Pollution Prevention and Abatement

Handbook 1998.

l/OO12204/EA/2204FinaAppAO20501 .doc Golder Associates


5.0 CONCLUSIONS AND PROPOSED ACTIONS: NIGERIANENVIRONMENTAL POLICY FRAMEWORK

Conclusions on the Nigerian policy and institutional framework evaluation, and proposed

actions to address areas of concern are presented in subsequent sections, and summarized

in Table A-1.

5.1 Environmental Assessment

The statutory requirements for environmental assessment of new projects are

unambiguous, and the accompanying guidelines present the screening, scoping,

preparation, and review process in ample detail. The screening guidelines reference the

need to protect a comprehensive list of sensitive habitat types, and the EIA report format is

comparable to the World Bank's. In conclusion, if national guidelines are followed, no

further strengthening of national environmental assessment requirements is required to

assure adequate EA review of Project related issues during future investment activities.

Implementation issues and policy support recommendations are summarized below.

5.2 Numeric Standards

The Nigerian regulatory framework has numeric standards both for ambient environmental

quality as well as for emissions and effluents. Individual standards are comparable to

those of the international lending institutions, and are considered adequate safeguards for

environmental quality if used for environmental assessment and compliance purposes

during future investment activities; especially since transmission line construction and

operation will generate little in the way of emission and effluent streams.

5.3 Protection of Wildland Habitats

Though the Nigerian screening guidelines identify a comprehensive list of habitat types

regarded as Environmentally Sensitive Areas, no further guidance or regulation is provided

1/O0/2204/EAI2204Fina]AppAO2050 .doc Golder Associates


on how potential impacts to these areas can be addressed during EA preparation.

Regulatory protection is afforded to formally protected areas, but not to habitats such as

wetlands or tropical forests outside the boundaries of those areas. Impacts to unprotected

natural habitats is not likely to occur during future investment activities that do not involve

significant new land conversion. Greenfield projects, especially high capacity transmission

lines, may result in direct impacts to natural habitats as a result of

The EIA terms of reference for greenfield transmission line projects will require the

identification of any natural habitats along proposed corridors as part of baseline

evaluation. Impact assessment and mitigation measures will include avoidance of any high

value habitats, including those listed in the Nigerian screening guidelines, or compensatory

protection of other, comparable wildlands in the case that impacts cannot be avoided. The

TORs will draw upon and reference relevant World Bank literature, including OPN.

5.4 Public Consultation

Though the Nigerian environmental assessment guidelines reference public participation

and communication as primary EIA objectives, the mechanisms to carry out this objective

are not well defined. In the absence of a defined process, the public consultation practice

has evolved into an open door policy for EIA technical review meetings, with no specific

effort directed towards consultation with stakeholder communities.

It is unlikely that public consultation will be required for projects that do not entail

large-scale land use changes, such as the installation of new capacity within existing

substation perimeters, or co-location of new transmission lines in existing corridors.

Greenfield projects, especially the construction of new, high-capacity transmission lines,

bring a high risk of involuntary resettlement or economic displacement. Accordingly,

public consultation will be carried out during the issues scoping phase of EIA

development, in parallel or preparatory to with socio-economic baseline studies.

1/00/2204/EA/2204FinalAppAO2050t .doc Golder Associates


EIA terms of reference will include a description of required public consultation activities.

The TORs will draw upon World Bank guidelines on the subject, including the Operational

Sourcebook Update No. 5 Public Involvement in Environmental Assessment.Requirements,

Opportunities and Issues.

5.5 Involuntary Resettlement

As summarized in Section 4.1.3.4, and described in detail in Attachment B, considerable

experience resides within NEPA on resettlement issues. However, the NEPA approach

has not historically complied in full with World Bank requirements as contained in

OD 4.30. The recommended policy actions of the Resettlement Action Plan Policy

Framework are to bring these NEPA practices into compliance with World Bank policies,

as well as to implement the processes provided under OD 4.30, including the iterative

preparation of Resettlement Action Plans with participation by affected parties at each RAP

development stage.

5.6 Cultural Property

The construction of linear facilities presents a risk of disturbance to any sites having

cultural significance along the alignment. However, no direct reference was found in the

Nigerian guidelines to the management of issues arising from archeological finds made

during the EIA process. This absence of policy guidance, plus the fact that Nigeria has a

long history of occupation, with significant trade-based urban developments in the north

dating back several centuries, creates the need for cultural resource protection during

future investment activities.

The TORs for the environmental impact assessment studies conducted on greenfield

transmission line projects will require a review of proposed alignments by a qualified

national archeologist. Should a risk to cultural resources be identified during this review,

spot checks of key areas will be conducted during EIA preparation. The construction

contract documents will also contain standard guidelines for responses to "chance-finds" of

I/00/2204/EA/2204FinalAppAO2050I .doc Gol der Associates


archeological resources during construction activities. These responses will include a

cessation of construction activity at the site of the find until professional evaluation can be

made of its significance; as well as notification to the appropriate agency of interest. The

TORs and construction contract documents will drawn on World Bank guidelines for

preparation, including the document Operational Management of Cultural Property in

Bank-Financed Projects Policy Note (to be issued as OP/ BP/GP 4. 1 1) No. 11.03.

5.7 Compliance Auditing and Environmental Management Planning

The Nigerian EIA guidelines refer to post-commissioning requirements for environmental

performance monitoring. Statutory requirement also exists to obtain a pollution discharge

permit, and to submit reports to FEPA on discharge parameters (S.I. 8 National

Environmental Protection [Effluent Limitation] Regulations 1991). However in practice

little post-commissioning evaluation of environmental performance occurs, and both NEPA

and FEPA personnel have little familiarity with either the management framework within

which it should occur, such as Environmental Management Planning, or the component

evaluation tools such as Environmental Audit. Exceptions to this may be the multinational

energy companies (e.g., Shell, Texaco) who have developed and implemented

environmental management policies on a corporate basis, and which translate into a

uniform practice for their operating companies worldwide.

As described in the EA report, the Project activities present some risk from the lack of

environmental management planning at substation sites. The proposed means of

addressing substation contamination will also address the larger issue of non-existent

environmental management planning on a sector basis, as described below.

Phase I audits will be conducted at each substation facility slated for activity under the

Project to determine the degree of environmental hazard, in turn principally related to the

likely presence of PCBs onsite. The audit scope will include workshop training of ESRU

personnel in environmental audit procedures. Training will include also include issues

I/OO/2204/EA/2204FinalAppAO20O50 .doc Golder Associates


associated with post-commissioning operation of transmission lines. A training objective

will be to create a nucleus of capability within NEPA for the monitoring of environmental

performance in the transmission line sub-sector. The workshop approach will therefore be

on the training-of-trainers. Sample TORs and checklists for the Phase I audits are attached

to this report (Appendix B and B-1).

The audit process is a tool for, among other things, determining the effectiveness of

environmental management planning. Since EMP has been absent at NEPA facilities, and

little capacity exists within the FEPA regulatory agency, additional training will be

provided to ERSU in this topic area. As with the audit training, one objective will produce

a nucleus of capability at the national level, which will be transferred to facilities

constructed with project funding (and potentially to the entire NEPA organization,

including generation facilities). A sample EMP table of contents is attached to this report

as Appendix C.

5.8 Institutional Strengthening

As referenced throughout this report, the staff of the ERSU have excellent empirical skills

in discipline areas applicable to environmental management, as well as experience in the

conduct of field surveys in support of resettlement planning. However, experience is

limited in the application of tools such as EIA, environmental audit and environmental

management planning. The ERSU is likewise in the early stages of organization, and

administrative responsibilities are not yet well defined.

5.8.1 Professional Capacity: Training Activities

Specific measures to strengthen ERSU institutional capacity for managing environmental

issues of Project activities are described below.

[/00/2204/EA/2204FinalAppAO2050 1.doc Golder Associates


* Workshop-based training will be conducted in each topic area ofenviromnental auditing and environmental management planning.

* International study tours will be conducted so the ERSU personnel can,among other activities, interview with professional counterparts intransmission sub-sector environmental management units elsewhere inthe world. Lessons learned in a developing country context may bemore readily transferable to the Nigerian situation than those gainedfrom state-of-the-art settings. Accordingly, this tour should not onlyinclude visits to power company staff in the developed world, but alsocounterpart staff in countries with relatively young environmental policyframeworks (e.g., Mexico). Lessons learned.

* A geographic information system (GIS) capability should be developedwithin the ERSU. GIS based on PC capabilities (i.e., as opposed toworkstation) can be acquired at a relatively low cost, and will greatlyincrease the utility of EIA baseline data, as well as the power of EIA asa decision making tool.

- Technical assistance to design, acquire and set up the GIS system will beprovided to the ERSU, as will applications training in GIS.

5.8.2 ERSU Organization and Administrative Responsibilities

Though the final organizational structure of the ERSU is still fluid, arrangements under

discussion include an administrative division into the following three divisions.

* A "Resettlement Division," further divided into "Operations" and"Valuation" units, which will be tasked with evaluating involuntaryresettlement and related compensation actions, as further described inAppendix A-1.

* An "Environment Division," which will be subdivided into a unit withresponsibility for "Compliance and Environmental Management," plusan "Environmental Assessment" unit responsible for EIA.

* A "Social Issues" unit that will be responsible for public consultation,public awareness and communication within NEPA on environmentalmanagement issues, and to serve as an official conduit for publicgrievances on environmental issues in the transmission subsector.

1/OOJ22041EA/2204FinalAppA02Q501idoc Golder Associates


Since there is a universal need for data on all areas of responsibility, it is proposed that the

GIS unit be placed under the supervision of the ERSU general manager.

Proposed responsibilities of the "Resettlement Division" are provided in detail in

Appendix A-1. Proposed responsibilities of the "Environment Division" are summarized

below.

The "Environmental Assessment" Unit will have the following responsibilities.

* Prepare "Project Proposal" reports for new project activities.

* On the basis of "Project Proposal" reports, conduct screening withFEPA to establish an EIA category

* Prepare TORs for EIAs on new projects,

* Oversee competitive bidding on consultant contracts to prepare EIAreports per the TORs

* Manage the EIA preparation process, with input from the Environment,Resettlement and Social Unit (ERSU) as appropriate, and includingoversight of the EIA review by FEPA

* Negotiate mitigation, compliance and monitoring requirements for newprojects with FEPA, and with input from the "Compliance andEnvironmental Management" division.

The "Compliance and Environmental Management" Division will be responsible for the

following.

* Evaluation of existing NEPA transmission facilities in terms ofcompliance with the Nigerian environmental regulatory and policyframework (with priority given to facilities slated for investment);

* Preparation of environmental management plans for each facility,including provisions for periodic monitoring and reporting;

1/00/2204/EA/2204FinalAppAO2050i .doc Golder Associates


> Oversight of the monitoring and reporting process, management of data,and provision of assistance to facility managers in obtainingenvironmental permits and submitting environmental reports to FME.

The Social Unit will have the following responsibilities.

* Collection and storage of secondary socio-economic data (i.e., in theGIS system) of relevance to the activities of the other two units;

* Preparation and execution of Public Consultation plans for use in theEIA process on new projects;

* Preparation and communication of a Grievance mechanism for use bythe public.

The "Resettlement Unit" will have a strong orientation towards the field, given the need

for ongoing interaction among stakehold groups. Accordingly, this unit will be divided

into Headquarters and "Zonal" components, with the latter having permanent presence at

the state and local government level (see Appendix A-1). Likewise, the "Social" unit will

have a public interaction role, and a local (i.e., "zonal") administrative component as well.

However, the Environmental Unit will likely become a centralized, headquarters-based

group that can be mobilized as needed to work at existing facilities, or at the site of new

project activities.

These administrative and organizational observations are of an initial nature. It is

recommended that expertise in institutional analysis relative to public environmental

management be contracted as a first Project activity to finalize questions such as the

optimal division of responsibilities and respective staff strength for the ERSU.

Costs for the implementation of environmental management activities are presented in

Table A-2.

1/00/2204/EA/22O4FinalAppAO2050l .doc Golder Associates


6.0 PROPOSED COST AND TIMELINE FOR STRENGTHENINGACTIVITIES

Estimated costs and timing of costs are presented in Table A-2.

1100122041EA/2204FinalAppAO2050 1.doc Golder Associates

TABLE A-2

ESTIMATED ENVIRONMENTAL STUDY AND INSTITUTIONAL STRENGTHENING COSTS FOR APL-1 AND APL-2

APL-1 Year I APIL-1 Year 2 APL-1&2 Year 3 1&2 Year 4 APL-2 Year 5 APL-2 Year 6

Cost Item Unit Rate I Cost # Cost Cost # Cost # Cost # Cost

1 Phase I Substation Audits: Osogbo, Kano, Onitsa °i $25,000 3 $75,000 _ . _ l

Phase 11 Audits: Osogbo, OniLsa $50,000 2 $100,000 _ _ ._._.

3 EIA Preparation Costs for APL-2 Transmission Line Projects $50,000 1 $50,000

Category 11 EIA $30,000 _1 $30,000 I $30,000 I $30,000 I

Category I EIA $75,000 _ _ $75,000 _ _

4ERSU Capacity Building: Institutional Analysis for ERSU $25,000 1 $25,000 _ ___

ERSU Capacity Building: In-country workshop training _ ___ _

- Phase l/Il/Compliance Auditing $25,000 1 $25,000 _ ____

7 - Environmental Management Planning (ISO) $25,000 1 $25,000 _ _ _

8 - Environmental Assessment Training for the Power Sector $25,000 1 $25,000

- Other In-Service Training $25,000 _ $25,000 I $25,000 1 $25,000 I $25,000

10 ERSU Capacity Building: International Training (per person) $10,000 4 $40,000

11 ERSU-based GIS System for Transmission Line Siting _ _ .______

12 - Equipment & Software Procurement LS 60000

13 - Secondary Data Acquisition LS 10000

14 - GIS Training $25,000 1 $25,000 I $25,000 ___

15 - GIS System Maintenance/upgrade LS $10,000

16 Lab Testing Costs LS $10,000 . $20,000 $10,000 $10,000 _ $10,000

17 Misc. Field Equipment (camera, video, presentation capability) LS $10,000 . _

18 Misc. Office Equipement (PC, printer, software etc) LS $20,000 _ _ _

19 _Vehicles $30,000 2 $60,000 _ _

70_Vehicle Maintenance ( _10_%) _ . $6,000 $6,000 $6,000 $6,000 $6,000

2 Yearl Totals __$465,000 $101,000 $181,000 $71,000 $71,000 $51,000

B_Grand Total _ $940,

Includes preparation of site Environmental Management Plans

1/00/2204/EA/AnA-TableA2.x1s Golder Associates

TABLES

February 2001 Golder Associates1/00/22041EAI2204FinalO20502.doc

TABLE A-1

REPORT CONTENTS COMPARISON (FME AND OPN 4.01) AND POLICY ACTION

Reference ReferenceNo, Issue/Policy Area World Bank Nigeria Comparison/Comment Policy ActionI New Project EA OP 4.01 Decree No. 86- Decree No. 86 contains guidelines Training of ERSU

Environmental Impact with EIA component sections personnel in EIAAssessment Decree of comparable to those of the World preparation1992 Bank.

2 Supporting Regulations Pollution Prevention Neither APL-I or APL-2 will Use national ambientfor Ambient and Abatement produce significant effluent or environmental qualityEnvironmental Quality Handbook emission impacts standards

3 Supporting Regulations Pollution Prevention S.I. 8 National S.I. 8 provides a schedule of Default to W. Bank noisefor Emission/Effluent and Abatement Environmental sector-based numerical effluent emission standardQuality Handbook Protection (Effluent and emission standards; effluent

Limitation) Regulations standards only for electric sector. Use national emission and1991 No noise emission limits. effluent standards for other

parameters during EIAS.I. 9 National S.I. 9 provides guidelines and preparationEnvironmental format for pollution dischargeProtection (Pollution permitAbatement in Industriesand FacilitiesGenerating Wastes)Regulations 1991

4 Policy support for OP 4.04 Procedural guidelines No standalone statute or policy Default to OP 4.04 andProtection of Natural Sourcebook Series for screening during EA document has been found Sourcebook Policies forHabitats, Bio-Diversity (FEPA 1995) state that providing explicit protection of preparation of greenfieldand Wildlands OP 11.02 Wildlands project location in mitigation requirements for transmission line EIA

Environmentally impacts to habitats other than in TORsEnvironmental Sensitive Areas (ESA) protected areas.Assessment Update trigger full EIANo. 20 (Category I)

5 Policy or Regulatory OP 4.01 EA Guidelines Decree No. 86 - EIA No detailed guidelines exist for Formalize publicSupport for Public Decree of 1992 contains conduct of public consultation. consultation process withConsultation provisions for Public guidelines to be

Hearing on certain Practice is to i) make EA reports incorporated into EIA termstypes of projects. available for public review in local of reference. Reference

government offices (i.e. near World Bank Operational

1/00/2204/EA/AppendixTableA .doc Golder Associates

7 R77eflenece pgleference No, W e C Ctoicy Ac ti

Supporting Procedural project site), as well as in regional Sourcebook Update No. 5Guidelines includes FEPA offices, and ii) look for apublic consultation as a list of persons consulted in the EAstep of EA preparation report.

6 Policy support for OD 4.30 Land Use Act of 1978 Land Use Act provides for full Training and capacityaddressing involuntary (modified in 1990) replacement cost of property, as building to improveresettlement issues has been implemented with large implementation of existing

national (NEPA) staff having policy framework.'experience from previous hydroprojects. Historic compensationhas, in practice, sometimes beenmade at less than full replacement.

7 Policy Support for OP/BP/GP 4.11 None encountered Develop EIA terms ofProtection of Cultural during EPFR reference to provideProperty preparation protection of cultural

resources, based onOP/BP/GP 4.11

8 Environmental OP 4.01 Annex C: Decree No. 86 (EA), No compliance monitoring or Strengthen compliancecompliance monitoring Env. Action Plan procedural and sectoral other ongoing environmental monitoring capacity

guidelines reference quality monitoring is practiced at through development ofEnvironmental requirement for post- NEPA facilities audit protocols andSourcebook Update commissioning training;No. 25. monitoring and

compliance auditing. Promote internal policy ofEnvironmental annual complianceSourcebook Update S.I. 9 National monitoring andNo. 11 Enviromnental commissioning of

Protection (Pollution independent auditsAbatement in Industriesand FacilitiesGenerating Wastes)Regulations 1991requires monitoring ofeffluents asresponsibility of wastedischarge permit

'Refer to Appendix A-1: Resettlement Action Plan Policy Framework

l/00122041EA/AppendixTableA .doc Golder Associates

FIGURES

February 2001 Golder Associates 003-22041/0O/2204/EA/2204Fina1O20502.doc

09 ~ ~ ~~ Z0

V3~~~~~

79.~~

......... .................. ....................o.................

APPENDIX A-1

RESETTLEMENT POLICY FRAMEWORK ACTION PLAN

February 2001 Golder AssociatesI/&ii22O41EAM04Fina1020502.dmc

APPENDIX A-1

NIGERIAPOWER TRANSMISSION DEVELOPMENT PROJECT

RESETTLEMENT ACTION PLAN POLICY FRAMEWORK

1. Project Description

1. The proposed Nigeria Power Transmission Development Project will provide62.2 million dollars IDA credit to Nigeria's National Electric Power Authority (NEPA)to help finance urgent power rehabilitation needs, expansion of national transmissionsystem, and power sector reform. The project will consist of three components: (1)investment component (US$56 million); (2) technical assistance component (US$5million); and (3) social and environmental component (US$1.2million).

2. For the investment component, the project seeks to redress certain networkdeficiencies and operational constraints of the Nigerian power transmission system.These measures will allow the efficient dispatch and transmission of the additionalpower expected to be available with the emergency and longer term measures nowbeing taken to increase generation availability. Specifically, the Investment componentswill include: (a) augmentations required at five main grid substations: Onitsha, Kano,Osogbo, Alaoji and Benin; and grid system reactive compensation; (b) installation ofgrid system metering at 132 kV to enable the measurement of power supplied tounbundled distribution companies; and (c) establishment of a new National ControlCenter (NCC) with SCADA/EMS facilities and associated communicationsrequirements. For the technical assistance component, it provides assistance forestablishing the new transmission and system operation company, and for developingtransmission and system operation-related secondary regulations. For the social andenvironmental component, it includes establishment of an Environment, Resettlementand Social Unit and an HIV/AlDS prevention awareness program.

2. Resettlement impact

3. There is no resettlement associated with this project. However as an input tothe early establishment of the Environment, Resettlement and Social Unit, and as abasis for preparation of future World Bank-assisted projects in the transmission sub-sector, the following Resettlement Policy Framework has been prepared.

3. Policy Objectives

4. The objectives of the policy framework include the following elements:(1) involuntary resettlement should be avoided or minimized through design efforts; (2)

where involuntary resettlement is unavoidable, resettlement activities should be conceivedand executed as sustainable development programs, providing sufficient investment

Appendix A-1

resources to give the persons displaced by the project the opportunity to share in projectbenefits; and (3) displaced persons should be assisted in their efforts to improve theirlivelihoods and standard of living or at least to restore them, in real terms, to pro-displacement levels.

5. Here, "affected people" refers to people who are directly affected socially andeconomically by a project through (a) the involuntary taking of land and other assetsresulting in: (i) relocation or loss of shelter; (ii) loss of assets or acess to assets; (iii) lossof income sources or means of livelihood, whether or not the affected persons must moveto another location; or (b) the involuntary restriction of access to legally designated parksand protected areas results in adverse impacts on the livelihood of the displaced persons.The policy applies to all displaced persons regardless of the total number affected or theseverity of impact. Particular attention is paid to the needs of vulnerable groups amongthose displaced: especially those below the poverty line, the elderly, women and children,indigenous groups and ethnic minorities.

6. If a project is World Bank-financed, the resettlement policy should apply to allcomponents under the project regardless whether or not they are directly funded by theBank. It should also cover resettlement resulting from complementary activities that arenot part of the Bank-assisted investment projects, but are necessary to achieve itsobjectives as set forth in the project documents.

4. Potential Resettlement Impacts Associated with Future Transmission Projects

7. Construction of new high voltage transmission lines (330kV and 132kV) andsubstations (330kV and 132kV) will involve a certain amount of land acquisition andresettlement. For transmission lines, a small amount of land area would be acquired forbuilding tower bases; and additional land would be needed temporarily during theconstruction for access road and storage sites. According to NEPA practice, in order toensure safe operation of transmission lines, all building structures and various treesunderneath the transmission line will be removed, within 30 meters of right of way for132kV transmission line, and 50 meters right of way for 330kV transmission line.Depending on the selection of alignment, the number of people affected and amount ofhome demolition needed would vary. A certain amount of damage to farm crops couldresult during the line construction. Farmers would be allowed to continue farming afterthe completion of construction. They will be compensated for the lost yield from thisland during the construction period. In addition, compensation would be provided forthe damage to crops within the right of way during future repairs or rehabilitation.

8. For the construction of substations, land area requirements range from 10hectares for 132kV substation to 30-50 hectares for 330kV substation. Depending onthe location of the substation and types of land occupied, the affected people may loseboth their houses and their farmland. In this case, alternative farmland and residentialplots would be provided for resettlement and rehabilitation. Table 1 provides a

2

Appendix A-1

summary of different types of investment projects, and their possible resettlementimpacts based on current practice.

Table 1. Types of Investnent Projects and Their Resettlement Impacts

Types of Projects Potential Resettlement Impacts1. Rehabilitation of (a) Change of equipment: (1) no new land required;

Substations (b) Expansion of substation:(1) no new land required if within the existing site;(2) new land required if exceeds existing boundary.

2. Restoration of 330kV! (a) Possible temporary impacts during construction on132kV Transmission crops under the transmission lines, or along access road;Lines

3. New Construction of (a) 330kV substation: acquisition of 30 - 50 ha. of landSubstations: area, plus access road;

(b) 132kV substation: acquisition of about 10 ha. of landarea, plus access road;

4. New Construction of (a) Land area acquired for tower base and access road330kV Transmission (permanent): 225 m2 per tower base, 0.068 ha. per kcm;Lines (b) Land area needed for construction (access road and

storage) --- ha. per Iam;(c) 50 meters of right of way clearance for safe operation:structures and economic trees to be removed; crops willbe cleared for tower bases and access road duringconstruction, but the farmers will be able to continueplanting afterwards;

5. New Construction of (a) Land area acquired for tower base and access road132kV Transmission (perrnanent): 25 m2 per tower base, 0.013 ha. per Iam;Lines (b) Land area needed for construction (access road and

storage) --- ha. per km(c) 30 meters of right of way clearance for safe operation:structures and economic trees to be removed; crops willbe cleared for tower bases and access road duringconstruction, but the farmers will be able to continueplanting afterwards;

Source: NEPA resettlement team.

3

Appendix A-1

5. Legal Framework for Land Acquisition and Resettlement

11. The legal basis for land acquisition and resettlement in Nigeria was the LandUse Act adopted in 1978 and modified in 1990. The following are selected sectionsrelevant with the land acquisition and resettlement.

Section 1. Subject to the provisions of this Act, all land comprised in theterritory of each State in the Federation are hereby vested in the Governor ofeach State and such land shall be held in trust and administered for the use andcommon benefit of all Nigerians in accordance with the provisions of this Act.

Section 2: (a) all land in urban areas shall be under the control and managementof the Governor of each State; and (d) all other land shall be under the controland management of Local government within the area of jurisdiction of whichthe land is situated.

Section 5 (1) It shall be lawful for the Governor in respect of land, whether ornot in an urban area - (a) to grant statutory rights of occupancy to any personfor all purposes;

Section 6: (1) It shall be lawful for a Local Government in respect of land not inurban area - (a) to grant customary rights of occupancy to any person ororganization for the use of land in the Local Government Area for agricultural,residential and other purposes; (b) to grant customary rights of occupancy to anyperson or organization for the use of land for grazing purposes and such otherpurposes ancillary to agricultural purposes as may be customary in LocalGovernment Area concerned.

Section 6: (3) It shall be lawful for a Local Government to enter upon, use andoccupy for public purposes any land within the area of its jurisdiction, and forthe purpose, to revoke any customary right of occupancy on any such land.

Section 6: (5) The holder and the occupier according to their respective interestsof any customary right of occupancy revoked under subsection (3) of thissection shall be entitled to compensation, for the value at the date of revocation,of their unexhausted improvements.

Section 6: (6) Where land in respect of which a customary right of occupancy isrevoked under this Act was used for agricultural purposes by the holder, theLocal Government shall allocate to such holder alternative land for use for thesame purpose.

Section 28: (1) It shall be lawful for the Governor to revoke a right ofoccupancy for overriding public interest.

4

Appendix A-1

Section 29: (1) If a right of occupancy is revoked ... , the holder and theoccupier shall be entitled to compensation for the value at the date of revocationof their unexhausted improvements.

Section 29 (3) If the holder or the occupier entitled to compensation under thissection is a community the Governor may direct that any compensation payableto it shall be paid (a) to the community; or (b) to the chief or leader of thecommunity to be disposed of by him for the benefit of the community inaccordance with the applicable customary law, (c) into some fund specified bythe Governor for the purpose of being utilized or applied for the benefit of thecommunity.

Section 29: (4) Compensation under subsection (1) of this section shall be, asrespects -(a) the land, for the amount equal to the rent, if any, paid by the occupierduring the year in which the right of occupancy was revoked;(b) buildings, installation or improvements thereon, for the amount of thereplacement cost of the building, installation or improvement, that is to say,such cost as may be assessed on the basis of the prescribed method ofassessment as determined by the appropriate officer less any depreciation,together with interests at the bank rate for delayed payment of compensation andin respect of any improvement in the nature of reclamation works, being suchcost thereof as may be sustained by documentary evidence and proof to thesatisfaction of the appropriate officer;(c) crops on land apart from any building, installation or improvement thereon,for an amount equal to the value as prescribed and determined by theappropriate officer.

Section 33: (1) Where a right of occupancy in respect of any developed land onwhich a residential building has been erected is revoked under this Act, theGovernor or the Local Government, as the case may be, may in his or itsdiscretion offer in lieu of compensation payable in accordance with theprovisions of this Act, resettlement in any other place or area by way of areasonable alternative accommodation (if appropriate in the circumstances).

12. According to the Land Use Act, all land in Nigeria is vested in the Governor ofeach State, and shall be held in trust for the use and common benefit of all people. Theadministration of land area is divided into urban land which will be directly under thecontrol and management of the Governor of each State; and non-urban land, which willbe under the control and management of the Local Government. The Governor of eachState will have the right to grant statutory rights of occupancy to any person for anypurposes; and the Local Government will have the right to grant customary rights ofoccupancy to any person or organization for agricultural, residential and otherpurposes. For agricultural purpose, no single customary right of occupancy shallexceed 500 hectares.

5

Appendix A-1

13. The Act gives the government the right to acquire land by revoking bothstatutory and customary rights of occupancy for overriding public interest. In doing so,the Act specifies that the State or Local Government should pay compensation to thecurrent holder or occupier with equal value. For NEPA as a federal governmentagency, it is also empowered by both Land Use Decree and NEPA Operational Decree(no. 24 of 1972) to acquire land for the purpose of effective operation. In doing so,appropriate compensations need to be paid in line with the existing Act. For any otherpublic or private enterprise, the process of acquiring land for development purpose willbegin with the application to the relevant Local and State Governments. After thereview of the proposed project, and suggested compensation levels, the LandDepartment of the State Department will approve the application for overriding publicinterest.

14. Since the Act gives the state ownership of all land, during land acquisition,compensation for land acquired by NEPA will be paid only for structures, installations,and improvements on the land, not land itself. However the Act does require State orLocal Government to provide alternative farmland for the affected people for farmingpurposes, or alternative residential plots for those who will lose their houses. In allhydro resettlement programs implemented by NEPA, such land replacement wascarried out.

15. However, in some transmission projects implemented by NEPA recently,alternative land was rarely provided for transmission line and substations projects.Compensation was paid for improvements, crops, trees, and structures within the rightof way. No special treatment was made for the land occupied by tower bases. Noalternative land was made available for the relocated people. In some areas closer to thecities, on a case by case basis, additional cash compensation was paid to the affectedpeople for replacing the lost building plots. For substation projects, for those who lostland and houses, additional cash compensation was paid to the affected people forrelocation and resettlement purposes, but alternative land was not provided by NEPA.

16. In order to ensure that the interests of affected people are fully protected NEPAwill ensure that whenever land is acquired (farmland or residential), alternative landwith similar location and size will be provided as replacement. The Local or StateGovernments will be responsible for arranging such land replacement, and NEPA willbe responsible for any cost associated with such land replacement. The project affectedpersons will choose such alternative land site with the agreement of local governmentand NEPA will bear the cost.

6

Appendix A-1

6. Compensation Rates for Structures, Assets, Crops and Trees

a. Structures and Assets

17. Although the Land Use Act does not specify detailed compensation rates for loststructures, installations or improvements due to land acquisition, it does provide basicprinciples for such compensation, based on replacement costs less any depreciation,together with interests at the bank rate for delayed payment of compensation. Inpractice a set of building compensation rates is often adopted by individual StateGovernments, which are applied throughout the State for development projects.Although such rates are adjusted periodically by the State to reflect changingconstruction costs, they appear to be low compared with the rates assessed by NEPA.For example, for a bungalow with modem facilities, the Benue State rate is betweenN2,000 to N4,500 per square meter, compared with NEPA assessed rate of N5,000 toN10,000 per square meter. Usually, the state rates are applied only to state-fundedprojects, and rates for federally-funded projects or privately-funded projects are higherthan the State rates.

18. In the actual implementation by NEPA property department, buildingcompensation is based on valuation for each affected structure. In the process ofvaluation of affected structures, the methods of replacement cost, comparable marketprice, and combination of these two were often used by NEPA professional estatesurveyors. Table 2 provides a recent example of compensation rates for differentbuilding structures in Benue State for a 330kV transmission line between Makurdi andAliade. According to NEPA staff, these rates seem to be accepted by the affectedpeople as fair compensation. However, because depreciation factor (up to 25 percent)was often considered in these compensation rates, and because alternative residentialplots or cost for preparing such plots were often not included, the actual payment couldbe less than the full replacement cost for the affected people, particularly in rural areawhere no market price is available for such structures.

19. To ensure that during project implementation, the affected people will beprovided full replacement cost for the lost structures, and are able to rebuild theirhouses without any difficulties, NEPA will estimate building compensation rates basedon full replacement cost without depreciation, and will be responsible for ensuring thatalternative residential plots are provided for affected people. Once individual projectimpacts are identified and valuation of individual structures are completed, detailedcompensation rates for different structures will be included in the resettlement actionplan.

7

Appendix A-1

Table 2. Compensation Rates for Building Structures in Benue State (1999)(Naira to Dollar: 1 USD = N100 in 1999)

type of structures Naira per square meter

detached home (duplex) 17,000 - 20,000semi-detached home 7,000 - 10,000bungalow 5,000 - 10,000boys quarters block 3,500 - 4,500generator house 2,000 - 3,000gate/security home 2,000 - 3,000mud block walling home 2,000 - 3,500factory/warehouse block 7,000 - 15,000office space 5,000 - 9,500

Note: the range of compensation for each type of structure reflects different finishesand construction quality.

Source: NEPA Property Department.

b. Crops and Economic Trees

20. On the issue of compensation for crops, and economic trees, a set ofcompensation standards are normally specified by individual State Governments, whichis applied throughout the State for development projects. Each State adopts its owncompensation rates for different crops and economic trees. As a result, variation existsamong States on compensation rates. For example, compensation rate for yam farm,was set at N 15,000 per ha. in Benue State, and only N 2,500 per ha. in Plateau State;for cassava farm, it was N8,000 per ha. in Benue State and only N1,000 per ha. inPlateau State. More importantly, most States rates seem to be low in comparison withaverage yield and market price for these crops and economic trees. For example, theprice of yam farm could be as much as N50,000 to N60,000 per ha.; and the price ofcassava farm could be as high as N25,000 to N30,000 per ha. In actual implementation,NEPA often uses these State rates as the lowest limit for compensation, and makesnecessary adjustments to reflect actual situation when State compensation rates appearto be too low.

21. In order to ensure that the compensation rates for crops and economic trees areadequate for providing replacement value and restoring income and livelihood for theaffected people, during resettlement preparation, NEPA will consult with the affectedpeople, and make detailed assessment of compensation rates, which will take intoaccount the current yield and market price of different crops, as well as the replacementcost for economic trees. Such compensation rates will be included in the resettlementaction plan.

8

Appendix A-1

c. Other Compensation and Assistance

22. For any loss of infrastructure facilities and community services, such as roads,bridges, schools, electricity, water, and so on, NEPA will provide in-kindcompensation by rebuilding these facilities to their original states. Such replacementwill be completed prior to the construction of transmission projects, so that the dailylife of concerned communities will not be affected.

23. For all affected households who will be relocated due to the demolition of theirhouses, in addition to providing replacement land for housing construction, eachaffected family will be given in-kind or cash assistance by NEPA to prepare the site,and construct necessary on-site infrastructures. In order to facilitate the moving for allrelocated households, transfer assistance will be provided by NEPA to the affectedpeople.

7. Criteria and Eligibility for Compensation

24. The compensation and rehabilitation will be provided for all affected people underthe following conditions:

(1) if their land or income source will be removed due to land acquisition for aproject;(2) if their houses or residential plots will be lost or partly damaged due to landacquisition;(3) if any other properties (crops, trees, and other facilities) or access to theseproperties will be removed or damaged due to land acquisition or construction fora project.

25. All affected people, regardless of their legal status, will be provided compensationand rehabilitation based on the policies adopted by NEPA. Lack of legal paper of theircustomary rights of occupancy certificates shall not be an obstacle for obtainingcompensation for them.

8. Institutional Arrangement for Resettlement Planning and Implementation

Institutional Context

26. Currently there is resettlement institutional capacity in NEPA. Such capacity ismainly concentrated in the resettlement department under the hydro power projectdivision of the generation sector, and the property department under the corporateservice sector. The resettlement department consists of 19 professional staff withplanning, economic, geography, and social backgrounds. They are mainly responsiblefor carrying out resettlement planning and implementation for hydro projects, such asJebba Hydro Project (12,000 resettlers) and Shiroro Hydro Project (19,000 resettlers).The staff of the resettlement department are familiar with the resettlement process,

9

Appendix A-1

including detailed socio-economic surveys, consultations with affected communities,and development of economic rehabilitation schemes for affected people. The propertydepartment is responsible for surveying different types of impacts and calculatingdetailed compensations. In the past, the property department staff have worked closelywith resettlement department staff in resettlement operations for hydro projects.However, for transmission line and substation projects with less impacts, the propertydepartment staff are mainly responsible for the resettlement implementation, which isoften conducted on cash compensation basis.

27. Within the property department, there are about 70 full time staff involved inland acquisition and compensation activities. They are located in two sections: (1)wayleave survey section, and (2) estate survey section. The wayleave survey section isresponsible for valuation of crops and economic trees; the estate survey section isresponsible for valuation of structures and attached properties. These staff are scatteredin different Zone offices of NEPA across the country with each office having 8 - 15staff. The staff from different Zonal offices are responsible for carrying out landacquisition and resettlement for the respective States. During the process of resettlementimplementation, NEPA's audit department is also involved when reviewingcompensation values and approving compensation payment to the affected people.

Environment, Resettlement and Social Unit (ERSU) of NEPA

28. An Environment, Resettlement and Social Unit (ERSU) will be set up withinNEPA, which will be part of the future transmission company. The unit should be dividedinto a headquarters unit and zonal units. The unit should consist of two sections:environment section and resettlement section, with 10 - 12 staff from both resettlementand property departments. The main responsibilities of resettlement section of ERSUheadquarters unit include:

(1) developing a resettlement policy framework;(2) organizing policy training for the resettlement staff in both ERSU headquarters

unit and zonal units;(3) organizing both socio-economic surveys and inventory surveys for each proposedproject;(4) preparing resettlement action plan for individual projects;(5) allocating resettlement funds to the respective resettlement zonal-units, after cross

checking with Audit staff;(6) supervising disbursement of compensation to the affected people by zonal-units staff;(7) organizing and carrying out internal resettlement monitoring for projects;(8) hiring independent institution for resettlement monitoring and evaluation.(9) assisting the design team in deterniination of final alignment to minimize resettlement.

ERSU Zonal-Units of NEPA

10

Appendix A-1

29. During implementation of a project, the ERSU will be supported by existingresettlement staff from both the property and resettlement departments in NEPA zonaloffices. There will be several dozen full time staff in zonal offices of NEPA. Each officewill be responsible for handling resettlement planning and implementation for individualtransmission projects in its region. Their main responsibilities will include:

(1) carrying out detailed inventory and socio-economic survey for the proposed project;(2) assisting the ERSU headquarter unit staff to prepare resettlement action plan;(3) consulting State and Local Governments and affected villagers on policies;(4) signing compensation contract and pay compensation to the affected people;(5) carrying out internal resettlement monitoring work for the project;

Measures for Reinforcing Institutional Capacity Under the Project

30. In order to improve institutional capacity for ERSU, its members will receivetraining such as participating in resettlement policy training and workshops onresettlement planning, implementation and income generation. The training activitiescould include (1) sending key ERSU staff to participate in resettlement and socialassessment training sponsored by the World Bank; and (2) inviting internationalconsultants or World Bank staff to Nigeria to carry out a series of workshops onresettlement policies, planning and implementation. Through these training activities,ERSU staff will gain a better understanding of international best practice and World Bankresettlement policies, and be better prepared to carry out resettlement planning andimplementation in accordance with new resettlement policy framework.

State and Local Government Agencies

31. During the process of resettlement planning and implementation, the concernedState Government agencies will be involved in the process. Specifically, they will

(1) participate in alignment selection;(2) participate in compensation policy formulation(3) help to resolve observed differences, such as compensation rates;(4) assist in allocation of alternative land and issue land certificates of occupancy;(5) resolve or report grievances to ERSU staff.

32. For affected Local Governments, they will also be involved in the process ofresettlement planning and implementation. Specifically, they will

(1) provide comments on alignment selection;(2) participate in compensation policy formulation;(3) assist in site selection of alternative land and issue customary rights of occupancy;(4) provide a liaison officer to work with ERSU staff;(5) witness the payment of compensation to individuals and communities;(6) resolve or report grievances from affected people to the State Government;

11

Appendix A-1

33. District Heads and Village Chiefs will also be involved in the process:

(1) assist in dissemination of information to affected people;(2) assist in the socio-economic and inventory survey;(3) witness the compensation to affected individuals and communities;(4) help in selection of alternative sites for replacement purposes;(5) assist in restoration of infrastructures;(6) resolve or report grievances to Local Government liaison officer.

9. Implementation Process

34. In terms of the process of resettlement planning and implementation fortransmission projects, there are seven basic steps to be followed by ERSU staff.

35. (1) Consultation with State and Local Governments. Establish initial contactswith relevant State and Local Governments by introducing a project, potentialresettlement impacts, and strategy or approach for compensation and rehabilitation.Such contacts allow the resettlement team to collect opinions or comments on theproposed project from the affected communities.

36. (2) Reconnaissance Survey. Preliminary identification of people affected by aplanned transmission project, which will be carried out in the field by a team ofresettlement staff and engineers in the design phase. Such survey provides an earlyestimate of resettlement scope for the project.

37. (3) Social Economic Survey and Detailed Inventory. Following the completionof demarcation on the ground for right of way or area for substation, a detailedinventory survey and social economic survey will be carried out within the affectedarea. During the survey, all impacts such as houses, land, trees, and crops, will becounted and measured, and affected households and people will be identified with theparticipation of the affected people. Along with recording all types of lost assets, trees,and crops, social economic information of the affected people and communities willalso be collected by resettlement staff.

38. (4) Develop Resettlement Action Plan (RAP) Based on the survey and agreedcompensation rates, the ERSU staff will calculate the compensation amount for eachaffected household, produce a detailed resettlement cost estimate, and prepare aresettlement action plan for the project.

39. (5) Consultation with Affected People. The resettlement plan and compensationpolicies will then be reviewed by relevant State and Local Government officials, withparticipation of district and village representatives. The comments and feedback fromlocal governments and affected people will be considered in the RAP finalization.

12

Appendix A-1

40. (6) Disclose the RAP policy to the Affected People. Inform the affected peopleand villages about the adopted resettlement policy and compensation standards once theRAP is approved. Public disclosure of the RAP could be carried out, for example, byholding public meeting, putting up notices in the affected villages, or distributingresettlement information booklets to the affected people.

41. (7) Sign Compensation Contract and Pay Compensation to the Affected PeopleThe final step of resettlement implementation should be started sufficiently before thecontractors enter the site, to give the affected people reasonable time to complete newhouses and move their belongings (e.g. 4-6 months). During the implementation, ERSUstaff will pay compensation directly to each affected household in the presence of localgovernment representatives.

10. Resettlement Funding, Cost Estimate, Flow of Funds and Contingencies

42. Resettlement budget for proposed projects will be fully included in the totalproject cost. In order to ensure that the resettlement program will be implementedsmoothly, during the resettlement planning, efforts will be made in developing realisticcost estimates for the resettlement program. The detailed cost estimated will be based oncomprehensive inventory survey of different impacts, and actual replacement cost forvarious types of compensation and rehabilitation. In addition, in order to ensure smoothimplementation of resettlement program, the resettlement budget will also include otherrelated cost, such as survey and resettlement planning, resettlement monitoring andevaluation, technical training, and overall administration. Given the time required forimplementation, and level of accuracy of the initial survey, a contingency fund of no lessthan 10 percent of total resettlement cost will be set aside for covering cost changes due toinflation or unexpected situations during the implementation.

43. In order to minimize problems in delivering compensation, ERSU will ensure thatthe flow of resettlement funds will be direct and transparent. Usually for compensation toindividuals, the funds will flow from ERSU through staff of Zonal Unit to affectedindividuals (head of household) witnessed by local government representative, districtchiefs and village heads. For compensation to affected communities, the fund will flowfrom ERSU through Zonal Unit to affected communities witnessed by local governmentand district chiefs. For the cost of restoring infrastructures and providing replacementland, ERSU will be responsible for carrying out the implementation and delivering theproducts to the affected communities and individuals.

13

Appendix A-i

11. Consultations with, and participation of, displaced persons in planning,inplementation

44. The consultation with the affected people will take place early in the process ofresettlement planning. Before the socio-economic survey of resettlement impacts isconducted, the resettlement staff from NEPA will carry out a reconnaissance survey toidentify the people and communities affected by the project. During the survey,comments and opinions of local governments and affected communities on the projectwill be collected and passed on to project planners. Continued consultation andparticipation will take place during the comprehensive social economic and inventorysurvey. During the survey, every affected household will be visited, and survey resultswill be reviewed by the affected people. In addition, in the process of developing theresettlement action plan, the local governments and affected people will be givenopportunities to review the compensation policies, rehabilitation measures, and makesite selection for the replacement land. Such consultation and participation will becontinued by ERSU staff through the resettlement implementation, which includesigning compensation contracts, delivering compensation to affected people, providingreplacement land, and restoring community infrastructures.

12. Grievance Redress Mechanism

45. The affected people will be given many opportunities to review the survey resultsand compensation policies during the process of resettlement planning andimplementation. However, during implementation, various issues might be encounteredby the resettlers. In order to resolve concerns effectively and quickly, a grievance redressmechanism will be set up. The affected people will be notified about such mechanismbefore the resettlement implementation.

46. Under the proposed grievance procedure, if a person is not satisfied with his orher compensation or rehabilitation measure, he could voice his complaint to the affectedvillage head or district chief. The village head or district chief will give him an answerwithin two weeks. If he still does not agree with the solution, he could appeal to theliaison officer of local government, who will given him a reply within two weeks. If hestill does not agree with the decision, he could appeal to the State Government andthrough them appeal his case to NEPA. The State and NEPA will make a decision withintwo weeks. If he still does not agree with the decision, he could go court as a last option.

13. Resettlement Monitoring and Evaluation Arrangement

46. Following the requirements of the World Bank, during the resettlementimplementation, both internal and external resettlement monitoring and evaluationexercises will be carried out in order to monitor resettlement implementation and ensureall affected people are compensated adequately and their income and livelihood arerestored after resettlement and rehabilitation.

14

Appendix A-1

Internal Monitoring

47. The internal resettlement monitoring will be carried out by ERSU and its ZonalUnit staff. The main purpose is for the transmission company management to have anoverview of the resettlement progress during project implementation. Every three months,local Zonal Unit staff will report resettlement implementation progress for eachtransmission line or substation project to ERSU headquarter unit. ERSU will compilethese individual project reports into an overall resettlement progress report for the wholeproject.

48. The report will include two parts. The first part is text section, which will providedetailed explanation on resettlementprogress, fund allocation, and issues and problems aswell as solutions in the implementation. The second part includes a set of tables, whichprovides a comparison between actual implementation for compensation delivered,amount of houses demolished, amount of new houses constructed, etc. and those in theresettlement action plan. In general, the internal monitoring will cover the followingaspects of resettlement implementation:

(1) the delivery and usage of resettlement compensation;(2) allocation of replacement farmland and residential plots;(3) reconstruction of new houses;(4) restoration of community infrastructure and facilities;(5) assistance for vulnerable group;(6) implementation schedule;(7) resettlement policies and compensation standards;(8) efficiency of resettlement institutions.

External Monitoring and Evaluation

49. For external resettlement monitoring and evaluation, an independent institutionwill be selected to carry out external resettlement monitoring and evaluation. The selecedinstitution should have extensive experience in social survey and resettlement monitoring.The main objective is by independently monitoring and evaluating the resettlementimplementation, to see whether the objectives of the resettlement policy are aclieved; andto provide basic assessment on resettlement implementation and restoration of livelihoodfor the affected people.

50. The scope of monitoring and evaluation includes the implementation progress,resettlement policies, delivery of compensation and replacement land, changes ofincome and livelihood among affected people, consultation and participation anddevelopment of local communities. The method of resettlement monitoring andevaluation will be based on a combination of sample household surveys and rapidappraisal in the field. The basic steps of monitoring and evaluation efforts include:

15

Appendix A-1

(1) developing detailed work plan according to terms of reference;(2) designing a survey scheme, including survey questions and survey forms;(3) conducting baseline survey among affected people prior to resettlementimplementation;(4) setting up information system for monitoring and evaluation;(5) carrying out monitoring and evaluation surveys on sample villages,households;(6) processing the survey data and analyze the survey results;(7) preparing resettlement monitoring and evaluation report (1-2 times a yearduring the project implementation).

16

Appendix B

APPENDIX B

SUMARY T'ERMS OF REFERENCE FOR SUBSTATION PHASE 1ENVIRONMENTAL AUDIT

Februarv 2001 Golder Associates 003-2204I/001)I204 IEA /2 204F inal(-0502. doc

APPENDIX B

SUMMARY TERMS OF REFERENCE FOR SUBSTATION PHASE I ENVIRONMENTAL AUDIT

1. Verify compliance with host country laws and * Take samples for verifying the state of ground orregulations, World Bank guidelines or accepted ground water.international standards for all important 3. Examine health and safety issues for both employees andenvironmental impacts. the local community.

* Review relevant existing and pending Examine procedures and rules for employeeenviromnental legislation, standards, and protection and assess the level of compliance withpermlts. company policies in the areas of noise, personal

*- Evaluate knowledge and awareness of, and protective gear, hot work and other potentiallyresponsibility for, applicable legislation. harmful activities.

* Examine compliance record with company * Evaluate accident/incident reporting, analysis andmanagement and with relevant government follow-up.authorities. * Check if medical examinations for employees

* Examine monitoring programs, procedures working in areas where they may be exposed toand controls in place. Assess the reliability dangerous substances are available. Check ifof data by evaluating monitoring design, particular symptoms or diseases are monitored.sampling strategy, calibration routines and patclrsmtm.rdsae ar moioe.qamplity ctrol procdures.tsaExamine the existence of asbestos in buildings andquEamityconerol procedures. forcorrectiveacequipment and procedures for dealing with* Examine procedures for corrective action asbestos.(including shut-down) if monitoring .Evaluate the adequacy of training and emergencyparameters are out of control limits. . * el_Examine if such incidents are to be, and drills for employees.actually are, reported, investigated, and * Examine record of complaints from the localfollowed up. Check if monitoring data are community and systems to follow these up.used for reporting to management or * Assess hazards or risks for the local community andgovernment agencies. Verify monitoring the adequacy of procedures for warning andresults or compliance by taking and analyzing emergency responses.representative samples.

4. Assess adequacy of internal controls, management

2. Eamine significant risks including chemical use, procedures and practices for dealing with thewaste management, risk of soil and ground water environmental, safety and health issues at hand.contamination, and fire and e-xplosion risks. Assess management awareness and commitment to

environmental issues.* Examine areas for storage of dangerous Ev alu iss ues

substances, fuels, and gases. Check warning * Evaluate adequacy and clarity of policies,systems, fire fighting equipment, labeling of objectives, targets and plans in the context ofcontainers, spill protection, and compatibility legislative requirements.of materials stored together. * Evaluate how well environmental goals areAssess procedures and controls in areas communicated, understood and implemented in thewhere dangerous processes occur. organization.Check safety data sheets for spills and Examine responsibilities for environmental laws andleakages, which should be available centrally regulations and the communication process withand at all points of use. enforcement agencies. Evaluate the roles and

' Evaluate adequacy of emergency procedures responsibilities for enviro.nental managementand contingency plans. functions.Evaluandconteingeofncpan * Assess document control procedures and the quality

' Evaluate skof naulhds e fld and use of records, procedures, registers andearthquakes, storms, landslides, etc. instructions.

> Perform a tour of areas where practices of * Examine feedback mechanisms in the form ofwaste management, storage and the use of corrective action systems, audit procedures anddangerous substances may have caused management reviews.contamination. *

* Reference: World Bank Environmental Assessment Sourcebook, August 1995. Update November 11.

1/oon2204/2W4AppB-020501.doc Golder Associates

APPENDIX B-1

CHECKLIST FOR PHASE 1 ENVIRONMENTAL AUDITOF SUBSTATIONS

February 2001 Golder Associates 003-2204I/0/2204/EA/2204FinaIO20502.doc

APPENDIX B-1

AUDIT PROTOCOLSUBSTATIONS

for:

National Electric Power Authority of NigeriaEnvironment Resettlement and Social Unit

sDIo0ossv 1OP1 0 9 -P zopoMladdvjoZwozoo,o

8S. .-----------..---------..--------------................................................. (3add) LN. Ndcllf3 AILDLOad 'IVNOSda3dSS ....................................................................................- NINIVEL MIAOAId S'IV 3VN SflO I ZVH

.--- . ---------.. ------..--------------..----..----- ..-- DiONINIV2[L aNV DNINNWId NOULVINflNNOO CWZVH

617........................................................IN3N3DVNVN 3lVm NW1OIS8t1'. . ---.. --.. ---.. ----------..---------------.............. NVId 3Hf1SV21WUNflO3 (INY IOQINOD 'NOIINaAgad TrIdS

9t........................................................... NOIJ1VZINVMO 'IO V'd9N3

vv 7.a3~SNV1l AJ3dOE1d

K 1--- -- SXNVI 39OVHS UNflOEDaOQNf

.r* - - - ---- - LSVM ciros

9.............................(.-.zH) Sid IOid3 IVlANI w Sd flSd

.------------------------------------- (Z-izH SXINVJ SSSJOXId w' 3DSO1OS ONflOEI 3AOW17. ------------------------ ----- (I-NzH) 311S NO U3Sfl x1o U3AIs)1 S'Wfl3IV sflo(rVZH

I.NOLLV~IO~{S '1V3N3D 10aW

l- xipuaddy ozIvu~~

Attachment B-iDecember 2000 -1- 003-2204

Auditor_

I. GENERAL INFORMATION

1. Site:

2. Contact person(s):

Phone/Fax:

E-mail:

Address:

3. Date and time of Site Visit:

Areas visited:

Areas not accessed:

Testing conducted for:ACMPCBOther

4. Describe surrounding areas

5. Descriptioni of property:

Property Owner:

Operations: _

6. Employee population:

7. Phase I environmental property assessment completed? On file?

w/On/2204AppB1-020501.doc Golder Associates

Attachment B-1December 2000 -2- 003-2204

8. Please provide facility plot maps with the following details noted:

- Total size of property

- Non-developed property

- Property boundary N

E

S

w

- Waste handling areas

- Chemical/material /equipment storage areas

- Access controls (i.e.,fences, guard shack, gates,etc.)

- Number of years at thislocation

9 Age, construction, & condition of the buildings, transmission lines, transfer stations, substation,transformers.

Facility Age

a.b.c.

10. Site history & previous activities, owners, & dates (begin with current owner)

Uses Datea.

b.

c.

m/o/2204AppB-020501.dc Golder Associates

Attachment B-1December 2000 -3- 003-2204

11. Known major changes to the facility Yeara.b.C.

d.

12. Describe and locate easementsa.

b.

C.

d.

13. Describe other locations where this facility has land and / or facilities used for storage ofequipment, supplies, products, wastes, chemicals:

14. Describe local ordinances that have impact on the environmental operations. (Only addressthose ordinances that differ from provincial and national mandates.)

15. List the Environmental Capital and / or maintenance projects planned at your facility.

EstimatedName Description Completion Date

16. Is vehicle fueling, bulk storage or distribution conducted on-site?

17. Is vehicle repair or servicing conducted on-site?

18. Site was first developed in?

UM1100104/22O4APpB1-020501.dac Golder Associates

Appendix B-IDecember 2000 -4- 003-2204

HAZARDOUS MATERIALS

1. Identify all of the hazardous materials received or used at this location on the following form.

HAZARDOUS MATERIALS RECEIVED OR USED ON SITE (HZM-1)

1/00/2204/2204AppBI1-020501 .doc Golder Associates


2. Identify all of the bulk storage tank materials and locations above ground. What are the bulk tank inspection schedules?

ABOVE GROUND STORAGE & PROCESS TANKS (HZM-2)

List the above ground storage & process tank(s) containing over 200 gallons of a hazardous material.

1/00/2204/2204AppB 1-020501 .doc Golder Associates


3. Inventory all sumps and pits.

SUMPS & INTERCEPTOR PITS (HZM-3)

1/00/2204/2204AppB I-020501.dm Golder Associates


4. ldentify and inspect all drummed hazardous material storage areas. (HZM-40

HZM4

DRUMMEMD HAZARDOUS MATERIL4 STORAGE AREA INSPECTIONAREA__ AUDITOR_

a. Are containers in good condition?

b. Are the drums properly labeled?

c. Is the material compatible with the containers?

d. Are drums covered/bungs secured?

e. Are drums containing flarnmable materials properly grounded?

f. Is the aisle spacing adequate? (4 ft)

g. How and where are the empty drums handled?

h. Dike/berm condition?

i. Any evidence of leaks/spills?

j. Floor drains?

k. Odors?

1. Chemical transfer points:paved?diked?storm water management?

UCOOWX4t224AppB1-20501.dmC Golder Associates

Appendix B-1December 2000 -8- 003-2204

m. Are fire protection systems available?

n. Is emergency spill response equipment readily available? Is it properly stocked with spill controlmaterials? Personnel Protective Equipment (PPE)?

o. Is the material handler familiar with emergency operations and equipment?

IJIXI/2204AppBI-0205OI.dAc Golder Associates

Appendix B-1Dece mber 2000 -9- 003-2204

1. Identify and inspect all bulk hazardous material storage areas.

2.

ATTACHMENT HZM-5

BULK HAZARDOUS MATERIAL STORAGE AREA INSPECTIONAREA R

a. Are the storage vessels in good condition?

b. When were they last inspected? PM?

c. Are they properly labeled?

d. What is the capacity and condition of the vessel dikes?

e. Is there any evidence of leaks or spills in the area?

f. Are there any odors?

g. How is storm water managed?Is the dike valve closed?Are discharge inspections records kept?

h. Describe the chemical transfer points.

i. Are fire protection systems available?

j. Is the emergency spill response equipment readily available?Is it properly stocked with spill control materials?PPE?

k. Is the material handler familiar with emergency operations and equipment?

1. Is the tank valve locked?

m. Is tank construction / material compatible with the substance stored in it?

u/20204/204AppB1-020501.d Golder Associates


6. If applicable describe the bulk loading procedure? Are there drains in the area? Verify employeetraining in the unloading procedures. (check records & talk to employee).

Once hazardous materials are received, describe the internal facility transfer methods

7. ]Does the facility ever store any "extremely hazardous substances" exceeding threshold quantities?If so, was the Local Emergency Planning Committee (LEPC) notified?

8. Did the facility ever release any "extremely hazardous substances" exceeding threshold quantities?If so, was the Local Emergency Planning Committee notified?

9. Document that the facility has reported their hazardous material MSDS or a list of MSDSinformation to the LEPC. Check for report completeness and accuracy.

10. ]Does the facility have any "hazardous substances" in excess of 10,000 pounds or any "extremelyhazardous substances" exceeding 500 pounds (approximately 55 gallons) or threshold planningiquantities?

11. How is the facility coordinator notified that there are new substances on site?

12. How are the facility pesticides/herbicides handled? How are they disposed? Where are theystored? Are pesticides mixed on-site?

13. Verify that the facility maintains records for technician certification.

14. Are all fire extinguishers free of halon materials?/OO04r22N4AppB1402MX1.doc Golder Associates


SOLID WASTE

1. What solid wastes (hazardous and non-hazardous) are currently generated at the facility? Are theyapproved? (ROG 95-1)

a. Cardboard -------|-- --

b. Waste Oil

c. Scrap Metal T---Id. Wood Pallets |

e. General Refuse | |

f.

h.1.~~~~~~~~~~~~~~~~~~~~~~~~

li.

j.

k.

1.

n.

0.

p.

q.

r.

S.

LM/12204/2204App8l -020501.doc Golder Associates


2. What waste transporters (hazardous and non-hazardous) are currently used at the facility?

a. Cardboard

b. Waste Oil

c. Scrap Metal

d. Wood Pallets

e. General Refuse

f.

g-

h.

1.

j.

k.

1.

m.

n.

0.

P.

q.

r.

S.

Solid Waste

1/0012204/2204AppB 1-020501. doc Golder Associates


3. What waste disposal facilities (hazardous and non-hazardous) are currently used by the facility?

a. Cardboard

b. Waste Oil

c. Scrap Metal

d. Wood Pallets

e. General Refuse

f.

g.

h.

1.

j.

k.

1.

m.

n.

0.

P.

q.

r.

S.

4. What is the facility's hazardous waste generator status? Review generation amounts for the year todetermine if there were any months during which the standard limits were exceeded.

a) generates < 100 kg/month and stores < 1000 kg at any timeb) generates between 100 & 1000 kg/month and stores < 6000 kg / 6 monthsc) generates > 100 kg/month

UOO/2204/2204AppB I-02050 1.doc Golder Associates


5. Describe any significant findings from a recent regulatory audit. Examine the audits summary.Verify follow-up of discrepancies. Have the appropriate personnel been notified?

6. Describe all notices of violations and related compliance schedules.

7. Are uniform manifests used for hazardous waste shipments? Are they properly completed? Howare they tracked?

8. Who is responsible to assure proper manifest completion? Who signs the manifests?' Examine themanifests for accuracy.

9. How long are the manifests retained on file?

10. If a manifest has not been received within 35 days, has the facility contacted the transporter andI'SDF to determine its location?

IoomO4m2AppB1-o2050.doc Golder Associates


11. Verify that all wastes have characterization analysis. Three years of records should bemaintained. Is the characterization in agreement with manifested shipments?

12. For each waste stream characterization describe:

a) the sampling method

b) the analysis parameters

c) date of analysis

d) who performed the analysis

13.Describe the procedure for identifying and classifying new waste streams.

14. How are the waste load weights obtained? (estimates, calculations, weight scales, etc.)

15. Inspect hazardous waste storage areas. Complete Form SW-1 for each location.

16. Verify that absorbent materials being disposed in landfills are inorganic and non-biodegradable.

Verify that no free liquids are present.

OO/22042MO4AppBI-020501.doc Golder Associates

Appendix B-iDecember 2000 -16- 003-2204

16. Verify that absorbent materials being disposed in incinerators are combustible. List BTU contentof waste.

17 Check that wastes designated for transport are packaged and labeled according to applicableregulations. Check:

a) package specifications

b) labeling & marking

c) shipping papers

I/=nX4/2204ApBI-O2O5OI.d=c Golder Associates


ATTACHMENT SW-1

HAZARDOUS WASTE STORAGE AREA INSPECTIONAREA

a. Are containers in good condition?

b. Are containers properly labeled & dated?

c. Is the material compatible with the containers?

d. Are incompatible wastes separated?

e. Ministry of Transportation approved drums?

f. Is the aisle spacing adequate?

g. Is the area near a sensitive environmental resource?

h. Dike condition?

i. Evidence of leaks/spills?

j. Is spill equipment, material, and PPE readily accessible?

k. Floor drains?

1. Odors?

m. Are any wastes stored over 90 days?

n. Are drums containing flammable materials properly grounded?

1/22n04AppBB1-20501.doc Golder Associates


23. How does the facility assure that the transporter has the proper placarding prior to shipping wastesoff-site?

24. Does the facility maintain placards for their shipments to be used should the transporter not be ableto supply one?

25. Describe all recycling efforts of hazardous materials.

26. ]Does the facility have a hazardous waste minimization plan? If so describe..

27. The hazardous waste minimization plan should include:

a) top management supportb) characterization of wastes & costsc) periodic plan assessmentsd) allocation of cost to generating dept. (optional)e) implementation

29. Inspect waste generation areas. (Use Form SW-2)

/W=2O4AWBI.-02M1.dW Golder Associates


ATTACHMENT SW-2

HAZARDOUS WASTE GENERATINGAREA INSPECTION

AREA

a. Are the containers compatible with the hazardous waste?

b. Are the containers in good condition?

c. How much waste material is at the generating point (55 gal/l qt)?

d. Are there floor drains in the area?

e. I[s spill equipment, material, and PPE readily accessible? _

fl Has the operator been trained in spill response and hazardous waste laws?Examine his understanding of the procedures.

g. Describe the hazardous waste transfer procedure from the process into the drums.

h. Are all of the containers closed, sealed, and labeled?

i. Are incompatible wastes separated?

j. Are fire extinguishers readily available?

k. Are drums containing flammable materials properly grounded?

* Complete for each hazardous waste generating area!

V0VMt2204/2204AMB1-020501.doc Golder Associates


30. Describe the Hazardous Waste training program. Who is trained? How often is training carriedout? Are course materials kept for 3 years beyond termination of employee? Are employeestrained within 6 months after employment or transfer? Examine the training outline. Verify withsign-in sheets. Are names and job titles included? Interview key "line employees" to verifycompetency.

31. How many employees have received training? Verify with training records. Interview employeesfor competency.

32. Have the above "certified" employees received annual refresher training?

33. Do all designated Emergency Responders have a baseline and annual medical physicals?

34. Is the facility's chain-of-decision command clearly defined? Who is the media contact?

110Or220U2204AppB1-02M1.doc Golder Associates


35. Describe the non-hazardous (general refuse) waste handling and storage procedures. Are theseprocedures included in an SOP? What measures are taken to ensure that hazardous waste is notmixed with non-hazardous wastes. Who is responsible?

36. Has the facility conducted an audit of all disposal & recycling vendors? Describe all recyclingefforts of non-hazardous material.

37. Has a general refuse study ever been conducted to inventory quantities and generation rates.

38. How are batteries disposed? What kind are they? How many are thrown out each month?

39. How are fluorescent light bulbs handled/disposed? How many are thrown out each month?

=ooMo4ro4AppBI-020501.doc Golder Associates


40.How much used oil does the facility generate in any given month?

41. What procedures are in place to separate used oil waste streams from hazardous waste streams?

42. How is used oil stored at the facility? (i.e., drums tanks, UST, etc.)

43. Is oil contaminated with CFCs or HCFCs stored in separate containers from other oils (not mixed)?

44. Is used oil recycled or disposed? (Includes metal cutting fluid)

45. Has the used oil ever been analyzed for total halogen content? If yes, was the concentrationgreater than 1,000 ppm?

46. How is oil-contaminated material drained and disposed?

47. Are used oil storage tanks and fill pipes clearly labeled as "USED OIL" ?

48. Does the used oil transporter have any required certification?

I/oo20G4fo4AppBI -20501. dc Golder Associates


49. Verify that absorbents used to collect oil and are destined for landfilling, are inorganic materials(clays, vermiculite, synthetic polymers). Oil absorbents destined for incineration are best organiccombustibles such as corn husk, sawdust, and nut shells.

50. How are used material drums handled? How/who determines if they are "empty". How areempty drums handled, stored, disposed? Is there a written procedure?

51. Does the facility have an empty container management program that takes steps to return or recyclec ontainers and ensure they are stored closed?

52. Are capacitors removed from the appliances before being scrapped? If they are, how are theydisposed?

53. Has the scrap dealer facility been inspected? Does the facility have all required permits?

54. Observe the disposition area for oil stains and spillage. Are there any impacts on storm water?

1/O0/2204t224AppB1-020501.doc Golder Associates


Auditor_

UNDERGROUND STORAGE TANKS

1. Have in-use or abandoned underground storage tanks (UST) been inventoried and has theappropriate agency been notified?

Do any of the underground tanks meet any of the following exemptions?

a) septic tanks

b) pipeline facility

c) equipment or machinery that contains regulated substances, such as hydraulic lift tanks andelectrical equipment

d) tank is in underground area (e.g., basement)

e) tank containing de minimis concentrations of regulated substances

f) emergency spill or overflow containment underground tanks system that is emptied afteruse

g) tank contains hazardous waste

h) tank is part of wastewater treatment facility

i) septic or other sewage treatment tank

j) storm water or wastewater collection system

k) surface impoundments, ports, ponds, or lagoons

1) flow-through process tanks

m) capacity is less than 110 gallons

UOM)4M204AppBI-MoWI.dm Golder Associates


UNDERGROUND STORAGE TANK INVENTORY

II(XJI22O122O4AppBdI Go

t~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~

Il00/2204/2204AppB 1-02050 1 .doc GolId er Assoc iactes


Auditor_

ASBESTOS

Given the age of the building or site, unbound asbestos is expected to be on-site Fe3

Insulation was observed on:type of insulation appeared to be

Walls i bergas sbesto ie

Pipes i i riberglas |esbesto t

Pipe elbows i i ribergiass sbesto ie

Roof bergeas sbesto t

Other bergas sbesto the

Conmnent:

Insulation which appeared to be asbestos was: jabi ot friabi

Other locations observed:

1. Has an Asbestos Containing Materials (ACM) investigation and inventory been conducted at thefacility? Locate "high hazard' ACM.

1==lt2X4t2204AppB1-020501.doc Golder Associates


2. Has a management plan been developed? Does it contain:

a) dates of ACM inspection and re-inspection

b) assessment description

c) total ACM quantities

d) sample locations

e) copy of analysis

f) signature of inspector

g) a detailed 0 & M program

h) an emergency fiber release procedure

i) worker notification / information effort

3. I)oes the facility have a periodic inspection program? Verify inspection record keeping.

4. Are the locations in which ACM is located throughout the station noted on construction drawings?

5. Is there a record keeping system for repair and re-inspection? Are any deficiencies identifiedduring inspections & documented?

6. Does the site have an annual program for the ACM awareness training?

I/00WI=4MO4AWB1-02501.doc Golder Associates


7. Are disposal location methods in conformance with international; best management practices orNational standards? Verify that the disposal locations and methods are in conformance with thosestandards.

8. Is there an active or inactive on-site ACM containing material burial area?

9. Has there been any demolition or renovation involving asbestos?

10. Are all health and safety standards being followed during abatement projects?

11. Have all employees designated to work with ACM had a proper training, respirator approval, andinedical records?

12. Do the asbestos abatement contractor specifications conform to National required conditions?Examine the contractor projects.

1=0012204/2204AppBl-MIl.doc Golder Associates


13. Are employees aware of the locations where asbestos is present to prevent them from workingthere unknowingly?

14. Is there a procedure in place to prevent employees from doing maintenance or construction work inareas where asbestos is known or suspected to be present?

15. What precautions are being taken for controlling maintenance employees' exposure to brake pador clutch dust?

16. Are outside contractors notified when they will be working in an area containing asbestos? Whoconducts the asbestos removal work at the facility?

17. Are asbestos contractors and their employees licensed by the local or National government toconduct asbestos removal work?

15. Regarding fuel dispensing:

a) does the facility conduct any fuel dispensing operations

b) if yes, what is the throughput

c) does the facility have any vapor control systems

ot2204f2204AppI-020O0I.doc Golder Associates

Appendix B-i1December 2000 -30- 003-2204

Auditor_

TRANSPORTATION

1. Does the facility offer for shipment an amount equal to or greater than 3,500 gallons, or 468 cubicfeet of hazardous materials or hazardous waste in a single bulk shipment? OR Does thefacility offer for shipment equal to or greater than 5,000 lbs. of hazardous material or hazardouswaste that requires placarding in a single shipment?

2. If so, is the facility registered with the Ministry of Transportation.(MOT)? Verify registration.

3. Are M.O.T. registration application statements and M.O.T. registration certificates maintained onfile for three years? Verify.

4. Are all employees who load, unload, handle or are responsible for transportation of hazardousmaterials properly trained and tested?. Verify training records.

5. I)oes M.O.T. training material include all of the following:

a) general awareness with M.O.T. hazardous material regulations, recognition, andcommunication

b) specific functional training directly related to the employee(s) assigned hazmat tasks

c) safety training which includes spill response and employee protection as related to thehandling of hazardous materials

1umo4n204AppBI-020501.doc Golder Associates


6. Do hazmat training records contain the following:

a) employee's name

b) date of training

c) copy of or location of training material used

d) name and address of the trainer

e) certification that the employee has been trained and tested

f) a copy of the employee's completed test?

7. Describe the procedures used to identify and track hazmat training requirements. Do Employeesreceive initial M.O.T. training within 90 days after acquiring hazardous material job functions?Also, are all hazmat employees retrained at least every two years?

8. Verify that all hazardous material shipping papers and hazardous waste manifests are legibly"'printed" (manually or mechanically).

9. If the hazardous material I waste is a "mixture" or "solution" of two or more hazardous materials,are the names of at least two constituents most predominately contributing to the hazard listed withthe proper shipping name?

I/OW=C4f2204AMB11-MI.dw Golder Associates


10. Does the shipper provide the transporter with the proper emergency response information for allshipments of hazardous materials / waste (i.e., ERGs, MSDSs, etc.)?

1 1. Does emergency response information include or cross-reference the basic shipping description andtechnical name of the hazardous material / waste being shipped? Verify. Also, are theser eferences "printed"?

12. ]Do hazardous material /waste shipping papers include documentation that Emergency ResponseGuide (ERGs) or Material Safety Data Sheets (MSDSs) are provided with the shipment? (GoodPractice)

13.1)o all hazardous material shipping papers provide the required Emergency Response TelephoneNumber? Verify.

13. Is the emergency response telephone which is listed on the shipping papers manned 24 hrs / daywith someone "knowledgeable" about the shipment, emergency response procedures, materialcharacteristics, etc.?

14. Has the person / organization responsible for manning the emergency response telephone beenprovided with current information on the material/waste being shipped? Verify and describeinformation provided.

12mo4/2204AppBl-20o501 doc Golder Associates


15. I)escribe the facility's procedure for assigning proper hazard class and M.O.T. shippingdescription for waste and materials. Is there a written procedure? Review shipping departmentrecords and hazardous waste manifests to ensure procedure is followed.

16. D)escribe the process for handling and shipping "empty" drums. If "empties" are not "Cleaned &Purged" prior to shipping, do shipping papers reflect the previous contents of the container?Verify shipping paper.

17. Is there a procedure written for shipping "empties"? Review procedure.

[OOm04mO4AppB-020501.doc Golder Associates


HAZARDOUS MATERIALS SHIPPED

L/0012204/22O4AppBI-020501 .dIc GIlder AssociAmes

1o00n204u2204AppBs1-020501. doc Golder Associates


18. Verify that all containers of hazardous material or hazardous waste are marked with the propershipping name and identification number. Interview person responsible for these activities. Whattraining has been provided? Was the training job-specific?

19. Verify that labels are placed on containers (i.e., totes, drums, boxes, etc.). Interview personresponsible for these activities. What training has been provided? Was the training job-specific?

20. I)escribe the procedure used by the shipping department and / o r the Environmental departnent toensure all new hazardous materials are properly identified, classified, labeled and shipped. Is therea procedure written? Review written procedure.

I/OOQn20t20A"B1-M=1.d= Golder Associates


Auditor_

PCB

Given the age of the building(s) on-site, PCBs are expected to be on site Ye

Within The Building(S) The Following Was Observed:

Fluorescent Lights Site Owned Public Utility Other

Mercury Vapor Lights "e Site Owned Public Utility Other

Sodium Vapor Lights E @ Site Owned Public Utility OtherOil Filled Transformers E Site Owned Public Utility OtherCurrent Transformers Yei Site Owned Public Utility OtherAir Cooled Transformers e Site Owned Public Utility Other

Outside The Building(S) The Following Was Observed:

Fluorescent Lights "e 3

Mercury Vapor Lights "f N3Sodium Vapor Lights f 9

Oil Filled Transformers e

Current Transformers EAir Cooled Transformers

Site Representative Advised That The Site Has PCBs In:

Fluorescent Lights E N3

Mercury Vapor Lights ESodium Vapor Lights "e

Oil Filled Transformers E

Current Transformers

Label Code(S)

Labels Observed Indicated That PCBs Are In:

1/00224/22O4AppB1-020501.doc Golder Associates


Fluorescent Lights JWi 3

Mercury Vapor Lights rei 3Sodium Vapor Lights [fe 3

Oil Filled Transformers Yei N

Current Transformers [fe 3

1. D)escribe and locate all current PCB transformers, capacitors, and electromagnets on site. Is itnear the cafeteria? In an office area?

2. Describe and locate all former PCB transformers, capacitors, electromagnet sites. Did spillsoccur?

oon204r2204AppBI-020501.doc Golder Associates


3. Describe and locate all reclassified & PCB contaminated transformer sites. Did spills occur?

4. Describe the Voltage Protection system for on-line PCB transformers.

5. Describe all PCB equipment removal efforts and identify all disposal sites used.

Io4n224o4AppB1-020501.dm Golder Associates


Auditor_

LEAD-BASED PAINT

Given the age of the building or site, LBP is expected to be on-site i i

Paint was observed on:

walls P n

pipes i 3

roof i i

other i i

Comment

The condition of the paint appeared to be: oo eeling >i

Locations observed:

LBP is known to be at the site i 3

An :LBP survey has been completed at the site i i3

A removal program is in place Pe 3

IOO204/2204IAppB1-020501. Golder Associates


Auditor_

NATURAL ENVIRONMENT RECEPTORS

Wetlands

Wetlands are on site?Wetlands are on surrounding lands? NDociunents indicate sensitive lands are on site or surrounding lands Ye- F

If yes, explain

Surface water

Ponded water is on-site yes ncA lake is on-site yes ncA creek is on-site y ncA river is on-site yes _A ditch is on-site y nA stormwater collection pit is on-site e

If yes, explain

Stormwater from the site enters into:A lake ye nA creek y nA riverA ditch Ves iA stormwater collection pit i

If yes, explain

IMrl4MO4AppBl14205 Ldoc Golder Associates


Environmental issues with surface water quality?

Explain:

Soil and Groundwater

Based on site operations it is expected that site operations have impacted theSite subsurface? e

If yes, explain

Soil-fill

The site is at grade with surrounding sites: Fe

Comument

The site has been drilled and fill is on the site i 3

Commeent

1/04 22O4AppB1-020501.doc Golder Associates

Appendix B-IDecember 2000 42- 003-2204

Piles of fill have been dumped on the site: Pe 3Comment

Is fill or backfill expected to be on the site i iCommment

The site has been previously drilled P p

Soil testing previously conducted i i

When

How many holes

By who?

Groundwater testing previously conducted P i

How many wells

By who

When

Did you obtain a copy of the report (s)? E 3

Do you suspect the soil has been impacted by present off-site operations? Ei

Do you suspect the groundwater has been impacted by present off-site operations? Tei

Do you suspect the soil has been impacted by past on-site operations? Fei

Do you suspect the groundwater has been impacted by past on-site operations? Tei

uO22O42204APPBlM-02M.doc Golder Associates


Provide details:

Groundwater flows in which direction?_

Is there a sensitive receptor in the area? E i

Is there a cleanup proposed for the site? rei 3

Has one been previously conducted?

Provide details:

Do you recommend drilling be conducted at the site? E i

Why?

Are there access, height or other drilling restrictions at the site? YeR

Explain

rC on2204AppBI-020501.doc Golder Associates


Auditor

PROPERTY TRANSFER

1. Has the facility purchased or leased new property since the last audit?

U0lKn2NApI-pM1 .do Golder Associates

Appendix B-iDecember 2000 -45- 003-2204

Auditor

GENERAL ORGANIZATION

1. Name the management employees involved and who are integral in Environmental Affairs.Examine their job descriptions. Do they include environmental activities?

2. Does the operating organization sub-contract with other vendors to facilitate the day to dayoperations? (e.g. sub-contract permanent on-site maintenance)

3. How are on-site contractors informed & monitored on compliance with National environmentalprocedure? Examine the contractor orientation and sign-off statements. Does it includeenvironmental requirements?

4. In an emergency situation:

a) who acts as the station spokesperson to the media

b) is that person knowledgeable in media management

c) can that person quickly respond to an emergency

d) are there alternates?

Ufl0412042N4AppB1-020501.doc Golder Associates


Auditor_

WATER (General)

1. Water authorityAddress

2. Permit number

Exp. Date

3. Describe the waste water sources and quantity.

1/00/2204/2204AppB1-02050.doc Golder Associates

Appendix B-IDeceimber 2000 -47- 003-2204

4. What is the source of drinking water?

5. Is the facility required to submit monitoring reports to the Department of Water?(provincial/National)

6. Describe significant findings of any Audits.

7. Is the non-domestic waste water pre-treated? (e.g., oil/water separator, grit traps, clarifiers)

uMn224AppB1-020501.doc Golder Associates

Appendix B-1December 2000 48- 003-2204

Auditor_

SPILL PREVENTION, CONTROL AND COUNTERMEASURE PLAN

1. D)oes the facility have an "official" Spill Prevention, Control, and Countermeasures (SPCC) Plan?Is a copy located at the facility?

2. Who is responsible for the SPCC Plan?

3. What is the SPCC Plan date? Has it been reviewed and evaluated every 3 years?

4. What spill equipment/supplies are readily available?

5. Have there been any chemical/fuel/oil spills at the facility? Have they been reported?

6. Are appropriate containment and/or diversionary structures or equipment present? Discuss

UO/n2O4AppBI-Oa01.doc Golder Associates


Auditor_

STORM WATER MANAGEMENT

1. Have all storm water discharges to surface water and to separate municipal storm sewer systemsbeen identified? (create a Storm water Outfall Locations Plot Plan of all Outfall Locations)

2. I)escribe the site's storm water characteristics and discharge locations. Complete AttachmentH20-3.

3. Describe any storm water sampling effort and frequency. Are flow rates measured? Samplingmethods described? Storm event data collected? (date, duration, amount, intensity, preceding dryperiod)

4. Is a permit required? If so by what agency. When was it submitted? What type of informationwas submitted? Verify.

IIOn204/2204AwpBI-2noso.dwc Golder Associates


of

ATTACHMENT 1120-3

STORM WATER OUTFALL OBSERVATION(for each outfall)

OUTFALL

a. Is the outfall obstructed with debris or sludge?

b. Does the outfall appear to have any "non-storm water" flows?

c. Does the outfall's downstream area show signs of oil staining or discoloration?

d. Is there an inordinate amount of foaming at the outfall?

e. 'Is the water discolored, turbid or have an oil sheen? Describe!

f. Does the vegetation appear stressed? Describe!

g. Is there any aquatic life in the downstream mixing zone? Describe!

h. Is there any odor? Describe!

1100/Zt04r2204AppB1-020501.doc Golder Associates


Facility Rep.

5. Does the site discharge storm water to a large or medium separate storm water system? Include thefollowing:

a) name of the facility

b) contact person and phone number

c) location of the discharge

d) services provided at the facility

e) any existing permits

6. If the site has an individual permit, does it accurately reflect actual conditions with regard to:

a) discharge locations and plant areas from which drainage areas discharge

b) areas where outdoor storage and handling of hazardous materials occur

c) potential to contact other materials which may pollute or tend to pollute waters

d) types of materials handled

e) past site uses

f) description of any treatment methods or facilities (e.g., settling ponds, oil skimmers) orbest management practices

7. Are stormwater discharge conveyances (e.g., trench, piping) being used for the discharge ofwastewater other than storm water?

UW12204/224AB1-M2O501.doc Golder Associates


8. Does the plan include:

a) a drainage map of the facility

b) a topographic map of the site

c) a description of storage and disposal methods

d) spill response procedures

e) a listing of spills that have occurred

f) risk assessment associated with stored materials

g) site inspection procedures

9. Are flow rates measured for storm water sampling?

10. What sampling methods are used? Does storm event data include date; duration, amount,intensity, and preceding dry period?

11. 'Which of the two storm water control practices does the facility employ for truck/rail car loading Iunloading areas

a) secondary containment for the loaded material

b) weather protection of the area and drip pans at spillage locations and a strong SPCCplan

12. Does the facility employ the following storm water control practices for storage?

a) secondary containment for the material

b) vessel integrity testing

c) a strong SPCC plan

IMZZO4/nO4AppBI-020501.doc Golder Associates


13. Are the monitoring records kept? For how long and do they contain:

a) time, date and place of the sample

b) initials or the name of the individual who conducted the sampling

c) date of analysis and individual who did it

d) reference or procedures of analysis

e) analysis results

U=4ONA"ppBI-M4I.doc Golder Associates

Appendix B-1Decernber 2000 -54- 003-2204

Auditor

Health & Safety

Time Permitting. The following sections should be completed.

HAZARD COMMUNICATION PLANNING AND TRAINING

1-1 Does the facility have any of the following types of equipment: (please check appropriateboxes)

O 1) Electrical Systems;O 2) Welding equipment;0 3) Stairs, ladders or scaffolds;0 4) Platforms or lifts;O 5) Spray finishing booths;O 6) Electrostatic Equipment;O 7) Cranes, derricks or slings;E1 8) Powered industrial trucks;O 9) Hand or portable power tools; or0 10) Woodworking machines or other specialty machines?E None

1-2 Has the facility obtained a Material Safety Data Sheet (MSDS) for each hazardous chemicalstored on-site above the threshold planning quantity (TPQ) or developed a list of suchchemicals?O YesO No

1-3 Does the facility have an efficient method of compiling MSDSs or lists of hazardous chemicals?O YesO No

1-4 Is an inventory of hazardous substances used/stored in the workplace available to employees?O YesO No

1100fl204/22OAppB1-020501.doc Golder Associates


1-5 Does the facility have a formal safety inspection program?O YesO No

1-6 Are safety inspections conducted at the facility documented?O YesO No

1-7 Is there a system in place to ensure that corrective action is taken for any deficiencies foundduring safety inspections?O YesO No

1-8 Is there documentation confirming that deficiencies identified during a safety inspection havebeen corrected?O YesO No

1-9 Do facility safety inspections cover ALL of the following areas:O 1) Aisles and passageways;O 2) Compressed gases;O 3) Electrical power systems, distribution systems and wiring;O 4) Emergency Equipment;0 5) Emergency eye washes and showers;O 6) Fire Extinguishers;0 7) First Aid Equipment;0 8) Housekeeping;o 9) Personal protective equipment; andO 10) Storage of hazardous substances?O YesO No

HAZARDOUS MATERIALS EMPLOYEE TRAINING

2-1 Under normal working conditions or in an emergency, could employees be exposed to anychemicals in the workplace?O YesO No

I/W/204/204AppB1-020501.dc Golder Associates


2-2 Are ALL workplace chemicals handled only in unopened, sealed containers?O YesO No

2-3 Are facility employees subject to potential exposure to any toxic materials? Please review yourinventory of toxic substances. Note the exposure levels for each substance.O Yes, Please attach a list.O No

2-4 Are safety concerns and information communicated through ALL of the following means:El 1) Staff meetings within operations;01 2) Meetings involving employees;0 3) Workshops and formal training seminars; ando 4) Bulletins of special concerns; the facility newsletter or newspaper, manuals, etc.?O YesO No

2-5 Please document any other means by which safety concerns and information are communicatedto employees.

2-6 Is there a system in place for responding to employee safety concerns at the facility?O Yes, please describe:u No

2-7 Are safety performance trends, accident reports, employee complaints, and inspection reportsused to identify needed improvements in facility's and operations?O Yes, please describe:O No

2-8 Are employee safety meetings conducted?O YesO No

2-9 Are minutes and attendance records maintained for employee safety meetings?O YesO No

2-10 Are DANGER signs posted to warn of immediate hazards such as radiation or flammable Gas?O YesO No

UO4Od2Z4AppB1-00501.doc Golder Associates


2-11 Are CAUTION signs used to warn of potential hazards or to advise against unsafe practices?O YesO No

2-12 Are safety instruction signs used where there is a need for general instructions and suggestionsrelative to appropriate safety measures?O YesO No

2-13 Are slow-moving vehicle emblems used on vehicles which by design move less than 25 mph?O YesO No

2-14 Does each accident prevention sign conform to ALL of the following specifications:a 1) Corners are rounded or blunt and free of sharp edges, splinters or other sharpprojections;O 2) Fastening devices are located so that they do not constitute a hazard;l 3) The lettering on a sign is easy to read and the wording is concise and easily understood;

9 YesO No

2-15 Does the facility have a training program for employees who work with or near hazardousmaterials?

c YesO No

2-16 Have all employees who have ANY responsibility for preparing hazardous materials forshipment received the necessary training on regulation requirements?O YesO No

2-17 Is training of all new hazmat employees completed within 90 days after employment began?O YesO No

2-18 Have back-up employees been named and trained to properly prepare and handle hazardousmaterials at times when primary employees are not on the job?O YesO No

IO/Z!04/04AppB1-020501.doc Golder Associates

Appendix B-1Decernber 2000 -58- 003-2204

PERSONAL PROTECTIVE EQUIPMENT (PPE)

3-1 Are there any hazards at the facility capable of causing injury or impairment of any part of thebody through absorption, inhalation or physical contact?O YesO No

3-2 Do any operations at the facility require the use of PPE (e.g., gloves, goggles, hearingprotection, etc.)?O Yes, please describe:O No

3-3 Is PPE available at the facility for employee use?O YesO No

RESPIRATORY PROTECTION

4-1 Does the facility conduct any operations which require personnel to wear respiratoryprotection?

O Yesf Noo Unknown

4-2 Have potential hazardous air contaminants in the workplace been measured to determine ifpermissible exposure limits (PELs) may be exceeded?C YesO No

4-3 Are employees trained in proper use of respiratory protection?O YesO No

4-4 Have employees been fit-tested for respiratory use?O YesO No

4-5 Are respiratory protection records kept at the facility?O YesO No

UA/ZOn04/22AppBI-0205o1.doc Golder Associates


4-6 Has a medical monitoring program been established for employees required to use respiratoryprotection greater than 30 days a year?O YesO No

CONFINED SPACE ENTRY

5-1 Do employees at the facility perform any work that involves confined space entry?NOTE: A space containing a door or portal through which a person can walk may be classifiedas a confined space if the entrant's ability to escape in an emergency may be obstructed in somemanner and if the space is otherwise meets the definition of a confined space.O YesO No

5-2 Does the facility have any spaces which have ONE or more of the following characteristics:O 1) Contains or has a potential to contain a hazardous atmosphere;O 2) Contains a material that has the potential for engulfing the entrant;O 3) Has an internal configuration such that an entrant could be trapped or asphyxiated by

inwardly converging walls or by a floor which slopes downward and tapers to a smallercross-section; or

O 4) Contains any other recognized serious safety health hazard?O YesO No

5-3 Does the facility have any confined spaces which do not contain or do not have the potential tocontain a hazard capable of causing death or serious physical harm?O YesO No

5-4 Has a confined space permit program been established?O Yes, if yes answer the remaining questions in section 5.O No

5-5 Is the training program for confined space entry documented?O YesO No

5-6 Are all authorized entrants, attendants, and entry supervisors instructed in the hazards that maybe faced during entry including information on the mode, signs, or symptoms, andconsequences of exposure?O YesO No

I/COl=204/22M4AppBl-020501.doc Golder Associates


5-7 Is each member of the employee rescue service trained in ALL of the following subjects:O 1) The proper use of the personnel protective and rescue equipment;a 2) The performance of the assigned duties;0 3) The role and responsibilities of the authorized entrants; and0 4) Basic first aid and cardiopulmonary resuscitation?O YesO No

5-8 Does at least one member of the rescue service have a current certification in first aid and incardiopulmonary resuscitation?O YesO No

VOn/2Zo4/22o4ApB-020501.doc Golder Associates

Appendix C

APPENDIX C

ENVIR1ONMENTAL MANAGEMENT PLAN OUTLINE

February 2001 Golder Associates 003-2204I/0012204/EA/2204Final(20502.dx

APPENDIX C

ENVIRONMENTAL MANAGEMENT PLAN OUTLINE

1.0 Introduction2.0 Mitigation

2.1 Anticipated Significant Adverse Environmental Impacts2.2 Mitigation Measures

2.2.1 Related Impacts2.2.2 Design2.2.3 Equipment2.2.4 Operation

2.3 Environmental Impacts of Mitigation Measures2.4 Linkage to Other Mitigation Measures

3.0 Monitoring3.1 Monitoring Measures

3.1.1 Description3.1.2 Parameters3.1.3 Methods3.1.4 Sampling Locations3.1.5 Sampling Frequency3.1.6 Detection Limits3.1.7 Thresholds for Corrective Action

3.2 Reporting Procedures3.2.1 Early Detection3.2.2 Progress and Results of Mitigation

4.0 Capacity Development and Training4.1 Role of Site Environmental Units4.2 Staff Training4.3 Additional Programs

4.3.1 Technical Assistance Programs4.3.2 Procurement of Equipment and Supplies4.3.3 Organizational Changes

5.0 Implementation Schedule and Cost Estimates5.1 Mitigation

5.1.1 Implementation Schedule5.1.2 Cost Estimate

5.2 Monitoring5.2.1 Implementation Schedule5.2.2 Cost Estimate

5.3 Capacity Development5.3.1 hnplementation Schedule5.3.2 Cost Estimate

6.0 Implementation of EMP with Project

1/00/2204/EAI2204AppC-020501.doc Golder Associates

world bank documentdocuments.worldbank.org/curated/en/520631468775588865/... · 2016-07-17 ·...

Documents