ENVIRONMENTAL & SOCIAL MANAGEMENT PLAN

For 4 Nos.

PHCN-TCN Transmission Substations

Rehabilitation/Re-enforcement Projects under the NEGIP (Kaduna, Akangba,

Alagbon and Ikeja West).

PHCN-PMU

March 2009

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Table of Contents

1.0 INTRODUCTION 4

1.1 Project Background 4

1.2 Project Locations 5

1.3 ESMP Goals and Objectives 5

2.0 INSTITUTIONAL ARRANGEMENTS 7

2.1 Resourcing 7

2.2 Responsibilities 7

2.3 ESMP Guidelines 7

ESMP Audit Programme

ESMP Implementation Organogram 8

3.0 Details of Substation Rehabilitation/Reinforcement Work 8

4.0 Substation Risk assessment and Management 11

4.1 Project Potential and Associated Impact Identification 12

4.2 Impact Characterization 12

5.0 Impact Mitigation Measures 16

6.0 DETAILED DESIGN FOR CONSTRUCTION & INSTALLATION 27

6.1 Design Implementation 27

6.2 Land take and Vegetation Clearance 27

6.3 Foundation works/Land/Sand Filling & Surfacing 27

6.4 Use of Public Access Road 27

6.5 Sacred Archaeological Sites 27

6.6 Hydrological Properties & Drainage Protection 27

6.7 Pollution Control 28

6.7.1 Air Pollution 28

6.7.2 Water & Soil Pollution 28

6.7.3 Noise Pollution 28

6.8 Transport Operation 28

6.8.1 Pre-mobilization of Vehicles 29

6.9 Inspection & Maintenance 29

6.10 Quality Assurance / Quality Control 29

7.0 ENVIRONMENTAL MONITORING PLAN 30

7.1 Monitoring Objectives 30

Monitoring Programme 31

3

7.2 Regulatory Compliance Plan 32

8.0 Work, Safety & Health Plan 32

8.1 Use of Work Permit 32

9.0 Waste Management Plan 33

9.1 Waste Handling 33

9.2 Waste Type & Identification 33

9.3 Waste Minimization & Reduction 34

9.4 Waste Segregation 35

9.5 Waste Disposal 35

10.0 General Site Safety Plan 35

10.1 Journey Management Plan 36

10.2 Accident / Incident Management Plan 36

10.3 Emergency Response Plan 37

10.4 Consultation Plan 38

10.5 Communication Plan 39

10.6 Commissioning / Hand over Plan 40

11.0 Decommissioning /Abandonment Plan

Annex 1 Cost Estimates. LIST OF ANNEXES

Annex 2 Environmental and Social site specific conditions at

Akangba 330/132/33kV Transmission Substation.

Annex 3 Environmental and Social site specific conditions at

Alagbon 132/33kV Transmission Substation.

Annex 4 Environmental and Social site specific conditions at Ikeja

West 330/132/33kV Transmission Substation.

Annex 5 Environmental and Social site specific conditions at

Mando 330/132/33kV Transmission Substation.

40 45 47 49 51 53

4

ABBREVIATIONS

ALARP As low as reasonably possible

CBOS Community Based Organisations

ERSU Environment, Resettlement & Social Unit

EPIC Engineering, Procurement, Installation and Commissioning

EER Environmental Evaluation Report

HSE Health Safety and Environment

JHA Job Hazard Analyses

NEGIP Nigeria Electricity and Gas Improvement Project

NGO Non Governmental Organization

PCB Poly Chlorinated Biphenyl

PHCN Power Holding Company of Nigeria

PMU Project Management Unit

PPE Personal Protective Equipment

PRA Preparatory Rural Assessment

RCP Regulatory Compliance Plan

TCN Transmission Company of Nigeria

WWI Written Work Instructions

5

1.0 INTRODUCTION 1.1 Project Background This document presents the Environmental & Social Management Plan (ESMP) for the

proposed Substation reinforcement/rehabilitation projects under the World Bank

sponsored National Electricity and Gas Improvement Project NEGIP.

When initially conceived, NEGIP APL I was envisioned as providing PRGs for new gas-

fired generating capacity, financing construction of transmission lines, rehabilitating

existing generating stations, improving distribution, and, providing PRGs for gas

supplies. The project was originally classified in Category A and, as specific plant and

transmission line locations were not known, the borrower prepared and disclosed an

ESMF and RPF to guide safeguards work. The composition of APL I subsequently

changed; generation stations and associated new transmission lines are no longer

included, nor is rehabilitation of existing generating stations. The project focuses on

improving electric transmission and distribution, primarily by rehabilitating and

reinforcing existing facilities, and on increasing power generation by promoting

adequate, reliable supplies of natural gas through provision of PRGs for gas supply

contracts. The project has been reclassified in EA Category B. The likely overall

impacts of NEGIP in this phase are site-specific; few if any of them are irreversible; and

in most cases mitigatory measures can be designed readily. This document then is

aimed at improving the viability of investing in the Substation rehabilitation/reinforcement

from an environmental and social management perspective. By using this tool

effectively, the anticipated potential environmental and social impacts associated with

the substation projects will be minimized to the barest minimum thereby making the

projects more sustainable.

NEGIP is an Adaptable Program Loan (APL) aimed at assisting the Federal

Government of Nigeria, through a combination of partial risk guarantees (PRG), for gas

supply to generation stations and International Development Association (IDA)

investments and technical assistance aimed at improving and developing the Nigerian

power sector (substation reinforcement/rehabilitation, transformer repair shop and

distribution facilities improvement etc). It follows a programmatic approach, and will

consist of numerous investments broken into subprojects and guarantees over an

extended time period.

This ESMP provides the basis for managing the environmental and social issues

involved with the implementation of the substation subprojects activities, by

6

demonstrating how adverse and beneficial environmental as well as socio-economic

and health effects will be managed in all phases of the project implementation. It

therefore describes in specific terms how environmental, health and socio-economic

commitments to be encountered in the Project implementations will be handled.

1.2

These rehabilitation/reinforcement projects are to be carried out in existing PHCN /TCN

Transmission Substations in Alagbon, Akangba, Ikeja West all in Lagos State, Afam & Port Harcourt in Rivers State, Mando Road in Kaduna State, Kainji & Jebba in Niger State & Birnin Kebbi in Kebbi State as part of the efforts to improve

the Nigerian electricity transmission infrastructure. Site specific information are attached

as Annexes. Most of the facilities at these stations are old and (on paper) have out lived

their life spans. More so, the technology used in manufacturing most of the installed

equipments is old and have since been phased out by the manufacturers thereby

making it almost impossible to source their spares. The fact that most of the

transformers at some of these stations were installed way back in 1965 reveals a real

risk of PCB contamination in the event of Transformer oil spillage. This is so because

the transformer oil then in vogue contained PCB until it was discouraged during the

Stockholm convention of 1986. As from then, PHCN makes deliberate efforts not to use

transformer oil containing PCB. Despite this, there are fears that these old transformers

contain PCB since the transformer oil therein have not been totally drained at any

particular point in time.

Project Locations

As all PHCN transmission Substations are similar in lay out, equipment content and are

all under the same management (TCN), the content of this ESMP is applicable to all

Substations owned and managed by TCN-PHCN. For the purpose of this write-up, the

following 330/132kV Substations at (Mando Road, Akangba, Ikeja West, and Alagbon) were visited for direct data gathering. Brief on these Substations will be added in the Annex. Generally, the issues observed in these substations tally with

what obtains in other substations not visited so the content of this ESMP applies to all

other Substations owned and operated by PHCN. Should there be any rehabilitation

work or normal operations in those stations, this ESMP remains valid.

ESMP Goals and Objectives The Environmental & Social Management Plan of this aspect of the NEGIP project was

developed in line with World Bank and ISO 14001 Environmental Management System

(EMS) Specifications; other national and international regulatory requirements; and

PHCN Health, Safety and Environmental & Social Management System as documented

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in the filed Project ESMF with the Ministry of Environment of the Federal Republic of

Nigeria in 2009. The ESMF Objectives are to:

• Ensure that substation rehabilitation activities are carried out in such a way as to

avoid harms to PHCN employees, contractors and all other stakeholders that

may be affected directly or indirectly by the facility operations.

• Ensure that all hazards associated with the S/S rehabilitation and operations

have all been properly identified and assessed. Barriers militating against the

project established and material recovery and emergency measures put in place.

• Enforce safe and healthy procedures and practices in all operations and strive

towards an incident free workplace.

• Ensure that appropriate trainings are given to staff and adequate equipment are

provided to enable staff work in a healthy and safe manner.

• Maintain effective communication with all relevant parties and in particular

communicating ERSU issues to the entire workforce.

• Demonstrate visible PHCN management commitment to ERSU issues.

• Set clear ERSU targets to staff involved in the project. • Carry out regular review of ERSU performance against targets.

• Ensuring that all operations are undertaken with proper regards for the

environment, and strive to reduce environmental risk to a level that is as low as

reasonably practicable.

These objectives shall be achieved by:

• Ensuring compliance with all stipulated legislation on protection of the

environment.

• Integrating social and environmental issues fully into the project development

and operational philosophies.

• Promoting social and environmental awareness among workers and

communities around the project sites.

• Rationalising and streamlining existing social and environmental activities to

add value, efficiency and effectiveness to the Projects

• Ensuring that only environmentally sound procedures are employed during

the different project phases and associated activities

• Continuous consultations with relevant regulatory bodies (FMENV, relevant

State environmental protection agencies and other stakeholders), throughout

the projects’ lifecycles.

This ESMP shall remain a dynamic working tool throughout the construction and

operational life span of these Stations. It shall be reviewed with possible changes in

8

regulatory regimes and in the event of new policies or guidelines from PHCN, WB or the

Nigerian Environmental regulatory bodies. Periodic reviews and updating shall also be

carried out throughout the project lifecycle, to incorporate better management systems

and economic policies.

ESMP Audit Programme This audit shall be conducted on regular basis to monitor compliance with the project

ESMP. The scope will cover the major project activities including the overall

requirements throughout the life of the project. PHCN performance towards meeting

these requirement will be assessed.

Generally, the audit programme will be conducted bi-annually during construction and at

start up and every five (5) years during operations. The findings from these audits will be

reported to the site ERSU Manager and corrective action plans will be developed and

followed up for performance improvement.

2.0 INSTITUTIONAL ARRANGEMENTS 2.1 Resourcing

Environment, Resettlement and Social Units will be set up in PHCN-TCN and in all the

Substations to be rehabilitated. A site ERSU Manager shall be responsible for all ERSU-

related matters throughout the project period and later during project operations in order

to ensure compliance with environmental regulatory standards. For effective project

implementation, the site ERSU Manager shall work in liaison with the Contractors’

Engineers & Environmental Officers, and TCN site Engineers to form the Project

Management Team (PMT) and the team will report directly to the Project Management

Unit of PHCN during the construction period and later to TCN during operations period.

The Project implementation Organogram defining the line of Communication in the

proposed Substation rehab/reinforcement (NEGIP) Project is presented below. Responsibilities Power Holding Company shall retain the primary responsibility of ensuring that

environmental and social commitments are met throughout the project lifespan. The

company shall establish a schedule of responsibility and improvement on social and

environmental matters. . Environmental and social issues shall be seen as a line of

responsibilities for which all levels of personnel are accountable.

9

ESMP Guidelines The detailed preliminary ESMP guideline developed to cover the entire phases and

activities of the proposed NEGIP Project including responsibilities for implementation

are presented in the Organogram below.

Figure: Project Implementation Organogram

Manager ERSU (Regional)

Environmental Management (Regional sub-Unit) Health & Safety

(Regional Sub-unit)

Socio-Economic (Regional sub-Unit)

Environment / Safety Officer (Work Centre)

ERSU TCN HQ

10

PHCN is the parent body for the entire component Companies to be formed from the

former National Electric Power Authority (NEPA) of Nigeria. These are from the former

Generation, Distribution and Transmission Sectors of PHCN. In implementing this ESMP

for Substation rehabilitation and reinforcement projects under the NEGIP, according to

the unbundling plan of PHCN, the TCN will soon be an independent Company of its own

from PHCN. When this happens, TCN ERSU will become a full fledged ERSU at their

Headquarters level overseeing the 11 Nos. Transmission Regional Units in all the TCN

Transmission Regions in Nigeria. Each 330/132kV Substation has its own ERSUs

reporting to the Regional Units. Wherever the rehabilitation/reinforcements will be taking

place, it is expected that their ERSU will be reporting to their managing Regional

ERSUs.

TCN ESMP Implementation Organogram

The ERSU in the PMU are part of the TCN Hq. ERSU and are only carrying out their

Environmental and Social functions in project management under the PMU. As such,

they will formulate policies together with the TCN Hq. ERSU and eventually monitor how

TCN and its site Units will carry out these Policies. At the same time, they will ensure

that the TCN implements best practice as far as Environmental and Social issues

involved with Transmission Projects are concerned.

3.0 DETAILS OF THE SUBSTATION REHABILITATION/REINFORCEMENT

WORK These will involve the replacement of Power transformers, Isolators, Circuit breakers

and some other ancillary facilities. New Power Transformers will also be installed in

some stations in order to boost the capacity of some of the Substations since most of

the existing Transformers are already overloaded. In view of these activities, if proper

management of the social, environmental, health and safety issues are not taken care

of, the projects might not be as sustainable as required according to the World Bank

standard. It is based on this that this ESMP becomes very necessary.

This ESMP is therefore designed to address the environmental and social impacts that

might arise from the rehabilitation activities at the respective Transmission Substations.

It will also proffer solutions to the lingering environmental issues like house keeping, oil

spillage and disposal of scrap materials and also put in place a well trained

Environment, Resettlement and Social Unit (ERSU) that will ensure strict compliance

with World Bank, Nigerian and other International environmental standards in the day to

day running of the PHCN owned Substations.

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Figure 1: Scrap Materials Littering the Akangba Substation Premises.

Figure 2: Decommissioned, oil-filled Reactor at the Mando Road Kaduna substation.

Figure 3: Decommissioned CTs and insulators at the Akangba substation premises.

Figure 4: Stored Used transformer Oil at a section Akangba substation – note the dark patch

Part of the Substation taken over by weeds (Poor house keeping)

4.0 SUBSTATION PROJECT RISK ASSESSMENT AND MANAGEMENT For any Projects of this nature, Risk management is an integral part of the project

execution. The risks related to these projects’ execution and operations were identified

by a structured approach during the project planning stage. Risk assessment visits by

ERSU/Safeguard specialists were conducted in advance of implementation activities to

allow for risk resolution without work interruption during implementation. Results of the

risk assessments and the associated risks reduction measures were evaluated and

documented by the PMU-ERSU and appropriate levels of the TCN site management

staff in the affected substations. This document therefore is a product to be used for

reducing project risks to an acceptable level at a reasonable cost to TCN. Upon project

completion, all other unforeseen risks and their associated resolutions shall be

documented for handover to the site operations personnel who will take over the Project

and continue the operations of the completed facilities.

The responsibility of risk management for these projects during implementation shall lie

with both the Project Management Team (PMT) comprising of the PMU, the

rehabilitation Contractors and the TCN Site management. The environmental and social

monitoring by the PMU-ERSU will reveal if the Contractor project implementation

processes are being successful.

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The majority of the workers involved in the construction phases of the project will be

Contractors staff, therefore Contractor will pay particular attention to applying

appropriately controlled mitigation measures for their work. Contractors shall ensure that

their HSE system are in line with this ESMP Guidelines. The Contractors working with

Job specifications developed by PMU-ERSU will have direct responsibility for executing

the work using sound engineering fabrication, installation and commercial practices

while maintaining adequate controls. The designs will take into account applicable

Nigerian environmental laws and regulations, and in the absence of such, generally

accepted industry standards shall be used. The Contractors will develop operating

manuals and appropriate documentation regarding the proper operation and

maintenance of the facility for approval by PMU-ERSU. This data will be provided to the

PMU in a timely manner that facility-specific training can be given to the concerned

personnel prior to start-up. Details of what is contained in the Contractors’

environmental manuals will be used by the ERSU in monitoring the job of the

Contractors.

4.1 Project Potential and Associated Impacts

The potential and associated impacts of the NEGIP Sub-station

rehabilitation/reinforcement project is based on observed issues during the risk

assessment visits to the Substations and the FMENV sustainability criteria. The visit to

the mentioned Substations revealed the following:

1. That they are littered with scrapped materials of different kinds and also with

decommissioned spare equipments kept in the open.

2. There are evidences of Transformer oil spillage around the transformers and

also around where the drums of used Transformer oil are kept.

3. Environmental management at these stations is generally poor. There is no

order what so ever in the manner of attending to oil spillage, soil/under water

contamination, and scrap management within the Substation premises.

4. Staff are not generally aware of the hazards of PCB in transformer oil hence

Staff use it for washing hands after repairs and also as weed killers within the

Stations.

5. There are no Units properly established to take care of the Environmental, Social

& Occupational Health and Safety matters in these Stations.

6. Usage of Personal Protective Equipment is lacking.

13

7. Routine cleaning and maintenance of equipments are not properly taken care of

hence there are cob weds, dusts and dilapidation of equipments that are still in

service as a result of lack of proper house-keeping

8. Communication between the Stations and their host Communities are weak and

same with Emergency action plans needed in attending to emergencies.

The nature and duration of the various impacts of the project activities on the ecological

components were identified as follows:

4.2 Impact Characterisation

In order to further describe the nature and duration of the various project activities on

the biophysical and socio-economic environment, the identified impacts were further

characterised as direct / indirect, beneficial / adverse, normal / abnormal, short-term /

long-term, reversible / irreversible, cumulative and residual.

• Beneficial Impacts: these are impacts that would produce positive effect on

the biophysical or socio-economic environment.

• Adverse Impacts: these are impacts that may result in:

• Irreversible and undesirable change(s) in the social and/or biophysical

environment;

• Decrease in the quality of the biophysical or social environment;

• Limitation, restriction or denial of access to or use of any component of the

environment to others, including future generations; and

• Sacrifice of long-term environmental viability or integrity for short-term

economic goals.

• Direct Impacts: these are impacts resulting directly (direct cause-effect

consequence) from a project activity.

• Indirect Impacts: these are impacts that are at least one step removed from

a project activity. They do not follow directly from a project activity.

• Normal Impacts: these are impacts that will normally be expected to follow a

particular project activity.

• Abnormal Impacts: An impact is considered to be abnormal when it follows

a project activity as against sound predictions based on experience.

• Short-term Impacts: these are defined as impacts that will last only within

the period of a specific project activity.

• Long-term Impacts: these are impacts whose effects remain even after a

specific project activity.

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• Reversible Impacts: these are impacts whose effects can be addressed on

application of adequate mitigation measures.

• Irreversible Impacts: these are impacts whose effects are such that the

subject (impacted component) cannot be returned to its original state even

after adequate mitigation measures are applied.

• Cumulative Impacts: these are impacts resulting from interaction between

ongoing project activities with other activities, taking place simultaneously.

• Incremental Impacts: these are impacts that progress with time or as the

project activity proceeds.

• Residual Impacts: these are impacts that would still remain after mitigation

measures have been applied.

Table 4.1: Characterised Potential and Associated Impacts of the Proposed Substation Rehabilitation/Reinforcement Project of NEGIP

Project Activities & Environmental Aspects

Potential and Associated Impacts Character of Impact

Mobilisation of personnel,

materials and equipment to

project site

Risk of road accidents from increased

vehicular movement on local roads and

damage to the road by heavy vehicles to be

used

Adverse, direct,

normal, reversible,

cumulative

Socio-cultural conflicts due to differences in

customs of migrant worker and local

residents

Adverse, direct,

abnormal, short-

term, reversible

Changes in demographic pattern/disruption

of socio cultural pattern

Adverse, direct,

normal, reversible,

cumulative,

residual

Introduction of communicable diseases

(STDs, HIV, hepatitis b & c, TB & gastro-

intestinal) into the project communities

Adverse, direct,

normal, short-

term, reversible,

cumulative,

residual

15

Air/noise pollution from increased vehicular

movement

Adverse, direct,

abnormal,

reversible,

cumulative,

residual and short

term

Preparation of the Equipment

bases clearing at construction

points, within the Substations

and necessary point along the

access roads

Damage to lawns within the Substations

and also alteration in the stone chipping

layers covering the Substation switch yards

Adverse, direct,

normal, short-term,

reversible,

Loss of business hours and disturbance of

residents and staff along the access routes

during mobilization

Adverse, direct,

normal,

irreversible, long-

term residual

Employment of local labour Beneficial, normal,

long-term

De-vegetation/loss of vegetation at

construction points.

Adverse, direct,

normal, short-term,

reversible

Fuel Storage Soil/groundwater contamination from

accidental leak or spill of stored fuel and

transformer oil at camp/construction sites

Adverse, indirect,

normal, short-term,

reversible,

cumulative

Foundation for the transformers

and associated equipment

Soil erosion, dust and accident due to falls

and damage to vegetation/alteration in the

gravelled substation switch yard.

Adverse, indirect,

abnormal, short-

term

Noise and vibration from construction

equipment

Adverse, direct,

normal, short-term,

reversible

Respiratory tract infections due to inhalation

of dust and toxic fumes during construction

activities

Adverse, direct,

normal, short-term

Risk of electrocution and burns (to onsite

workers during construction)

Adverse, direct,

normal, short-term

Induced secondary development in the

substations (work camps/stores)

surrounding by Contractor during

construction activities

Adverse, direct, normal, short-term, reversible

16

Engagement of indigenous labour and

supplies and stimulation of local economies

Beneficial, direct, normal, short-term, reversible

Rehabilitation/Reinforcement of the Transformers and ancillary equipments

Youths/community restiveness especially

during recruitment of local labour

Adverse, direct,

abnormal, short-

term, reversible

Community restiveness during heavy

vehicular movement due to road congestion

and damages

Adverse, direct,

abnormal, short-

term, reversible

Decommissioning of old transformers, solid

wastes and spillage of the transformer oil

suspected to contain PCB

Adverse, direct,

abnormal, long-

term, reversible

Decommission and Closure Station

Electric shock and severe burns to workers

during decommissioning

Adverse, indirect,

abnormal, long-

term, irreversible

Impaired aesthetic resources due to visual

presence of wastes and scraps

Adverse, direct,

abnormal, long-

term, reversible,

residual

Direct poisoning of vegetation/soil

contamination due to uncontrolled

application of maintenance,

chemical/herbicide

Adverse, direct,

abnormal, short-

term, irreversible

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5.0 ENVIRONMENTAL IMPACT MITIGATION MEASURES FOR THE SUBSTATION REHABILITATION PROJECT Below is the table showing the intended mitigation measures for the key environmental

and social impacts of the NEGIP substation rehabilitation/reinforcement project.

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Project Phase / Environmental

Aspects

Critical Control Point Mitigation Measures

Action Party

Site 1.Preparation Mobilisation of

personnel, material

and equipment to

project area

Transportation vehicles

& routes

Contractor trucks shall be

properly

serviced/maintained before

mobilisation

♦ Contractor shall

mobilise heavy duty

trucks carrying

equipments in the night

to avoid traffic

delays/accidents

♦ Outriders shall be

engaged when

possible and used

during mobilisation of

heavy duty trucks and

equipment.

♦ Radio/TV

announcements shall

be made to inform the

general public of

activities/movements

♦ Contractor shall

engage and use traffic

control wardens at

strategic points on

local roads

♦ Strategic road

signs/warnings shall be

placed on local roads

♦ PHCN shall enforce

approved speed limits

on local roads among

its drivers and

Contractors’ personnel

ERSU

Manager/PMT

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Local roads

♦ Work sites

♦ Recreational

facilities

♦ Markets, etc.

♦ Contractor shall survey

and make use of best

road access to site and

repair damaged road

points/areas damaged

as a result of the

movement of their

equipment to site

♦ Contractor shall

educate its workers on

the socio-cultural

norms of the host

communities so as to

conform to laid down

customs and norms of

the local community

♦ Recreation areas

should be avoided by

vehicles carrying

equipments as those

areas are always busy

and they may cause

hold ups.

♦ The above situation

applies to market

places

ERSU

Manager/PMT

♦ ERSU

Manager/Comm

unity Relations

Officer

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Site Preparation Mobilisation of

personnel,

material and

equipment to

project area

♦ Base campsite

♦ Communities

♦ Prior to mobilisation,

Contractor shall screen

all personnel for

communicable and

other diseases

♦ Contractor shall

conduct a health and

safety awareness for

staff and host

communities

♦ Contractor shall carry

out periodic health

screening for staff

while on site and

identified cases shall

be promptly isolated

for proper medical

attention

ERSU

Manager/PMT

/ Community

Relations Officer

Operational Vehicles Contractor shall ensure

that its operational

vehicles are at optimal

operating conditions

Site HSE Co-

ordinator/ transport

supervisor

Site Preparation Vegetation clearing

at construction sites

Construction areas to

be cleared ♦ Contractor shall limit

vegetation clearing to

minimum area required

for the campsite,

construction site and

access roads

♦ Disturbed and

unwanted areas at

campsite, and access

roads shall be re-

vegetated with

appropriate local

species

Site

ERSU Manager/

Site Engineers

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Project Phase / Environmental

Aspects

Critical Control Point Mitigation Measures

Action Party

Site Preparation Fuel storage

Storage area ♦ Storage containers shall be

periodically checked for leaks

♦ Operators shall be trained on

safe fuel handling practice

♦ Containers shall be provided

with secondary containment

capable of holding 110% of its

contents

Site HSE

Co-ordinator

Construction Plinth for

transformer bases

and Installation of

other related S/S

equipment

Within the Substations ♦ Contractor shall employ best

engineering practice in the

excavation of the pits and for

ancillary facilities in order to

avoid adverse alteration of the

hydrological pattern of flow

♦ Dug up areas shall be promptly

and properly restored

Site HSE

Co-ordinator / Site

Engineers

Construction points ♦ Contractor shall maintain all

construction equipment at

optimal operating conditions in

order to reduce noise and

vibration

Site ERSU

Manager

HSE Co-ordinator/

Site PMT

Health and Safety at

excavation points ♦ Contractor shall design and

enforce workplace safety

procedures at sites based on

this hazard to prevent accidents

22

Project Phase / Environmental

Aspects

Critical Control Point Mitigation Measures

Action Party

Welding of

materials, erection

of transformers and

Installation/operation

of other S/S

equipments

Welding/construction

points

Specialized PPE shall be provided

and usage enforced during welding

activities

Site HSE

Co-ordinator/ Site

Engineers

Worksites ♦ Contractor shall design work

place procedures in line with

standard industrial practice

♦ Specialised PPE shall be

provided for all on site workers

ERSU

Manager/Site HSE

Co-ordinator/ Site

Engineers

♦ All pits/holes dug during

construction works shall be

appropriately filled.

Project Phase / Environmental

Aspects

Critical Control Point Mitigation Measures

Action Party

Welding of

materials, erection

of transformers and

Installation/operation

of other S/S

equipments

Campsite ♦ Contractor shall develop

comprehensive plan for location

of secondary development

ERSU Manager/PMT

Construction points ♦ Contractor shall ensure that its

construction equipment are

maintained and operated at

optimal conditions to reduce

emissions capable to air

pollution

Site HSE Co-ordinator

Installation points ♦ Contractor shall design, enforce

and maintain good work place

procedures in line with industry

standard and regulatory

requirement on safety

♦ Standard work instructions for

HSE critical activities shall be

developed and enforced

ERSU

Manager/Site HSE

Co-ordinator/ Site

Engineers

23

Point of mobilisation ♦ Prior to mobilisation Contractor

shall screen all personnel for

communicable and other

diseases

♦ Contractor shall conduct a

health and safety awareness for

staff and host communities

ERSU

Manager/Site HSE

Co-ordinator

Recruitment point

♦ Contractor shall ensure that the

content of the memorandum of

understanding between it and

the host communities on

employment are religiously

followed

ERSU

Manager/Communi

ty Relations Officer

Project Phase / Environmental

Aspects

Critical Control Point Mitigation Measures

Action Party

Welding of

materials, erection

of transformers and

Installation/operation

of other S/S

equipments

Transmission line ♦ Where transmission lines are to

be involved, Contractor shall

maintain the selected route for

the transmission line (with

minimal interference with areas

of human activity)

Site HSE

Co-ordinator

♦ Adequate and automatic

fault/damage detection system

shall be installed where possible

♦ Personnel shall be trained on

the detection/handling of such

emergencies arising from

shocks or accidental damages

Site Engineers

24

♦ Contractor shall install

specialised fire

detection/prevention equipment

at the substation

♦ Staff shall be trained on

emergency fire/explosion

handling procedure

♦ Contractor shall design and

maintain work place procedures

in line with industrial standards

ERSU

Manager/Site HSE

Co-ordinator Site

Engineers

Control rooms in the

Station (substation) ♦ Adequate and automatic

fault/damage detection system

shall be installed

♦ Personnel shall be trained on

the detection/handling of such

emergencies arising fro

accidental damages

Site Engineers

Project Phase / Environmental

Aspects

Critical Control Point Mitigation Measures

Action Party

Welding of

materials, erection

of transformers and

Installation/operation

of other S/S

equipments

Substation safety

♦ Contractor shall install

automated monitoring system

(CCTV) to check unauthorised

entry

♦ Emergency response plan shall

be put in place for such

developments as

sabotage/vandalism

Site Engineer/

Site HSE

Co-ordinator

♦ Contractor shall use only trained

and competent personnel for all

maintenance works

♦ Maintenance personnel shall be

provided with appropriate PPE

♦ Personnel shall be trained on

handling of emergencies

ERSU

Manager/Site HSE

Co-ordinator

25

Substation House

Keeping

♦ Substation environment shall be

properly maintained and kept in

good healthy condition.

♦ Lawns must be planted with

indigenous flower species and

grassed accordingly

♦ Management shall maintain

naturally low growing vegetation

within the Substations

♦ Management shall explore the

option of always using

mechanical maintenance

techniques

♦ For chemical maintenance

option, Management shall

employ selective herbicide

application

♦ Site Management shall maintain

appropriate gravelling level of

the Switch Yards

♦ Equipment must be in sound

working condition and cleaned

as at and when due

♦ Used transformer oil must be

disposed or stored as

appropriate in line with

regulatory requirements

♦ Solid wastes must be disposed

of by using appropriate waste

disposal companies and in line

with laid down rules

ERSU

Manager/Site HSE

Co-ordinator

26

Project Phase / Environmental

Aspects

Critical Control Point Mitigation Measures

Action Party

Substation site location PHCN shall as much as practicable

avoid locating Substations near

market/city centres, tourist

attractions and places of special

value and interest to the people.

ERSU

Manager/PHCN

Engineers

Decommissioning /

Abandonment

PHCN shall ensure that the

decommissioning and abandonment

plan for the Substations and the

proposed projects are implemented

in details as contained in this

document.

ERSU

Manager/PHCN

Management

27

6.0 DETAILED GUIDELINES FOR THE SUBSTATION REHABILITATION/REINFORCEMENT CONSTRUCTION AND INSTALLATION

This aspect of the ESMP is developed in such a way that it would be inserted in the Bid

documents for the intending Contractors to know what is expected of them during the

project implementation period. Based on their approved submission the PMU-ERSU will

monitor their site activities.

6.1 Project Design & Implementation The design of the proposed Substation Rehabilitation Project of (NEGIP) is based on

Power Holding Company/TCN Operations, Maintenance and HSE guidelines as well as

relevant technical specifications in agreement with standard power and electrical

industry practices. These philosophies identify relevant standards, codes, practices and

specifications that apply to the technical/operating specifications to be used for the

design, construction and operations of the proposed NEGIP Project. The guidelines also

address controlling deviations from approved standards, codes, practices and

specifications, and providing feedback to improved standards.

.

6.2 Foundation Works, Land / Sand Filling and Surfacing Work along access roads and construction site shall be carried out in such a manner

that there is no damage or interference with existing water courses or drainage systems,

utilities, structures, roads or other property of public or private, vehicular or pedestrians

access, other than to the extent that is necessary for them to be removed or diverted to

permit the execution of work within the defined operational perimeter. Any facilities

disturbed or damaged directly or indirectly due to foundation works, site excavations,

land/sand/gravel filling and surfacing activities shall be restored to the original condition.

The clean up and restoration plan shall be in accordance with regulatory requirements.

If existing watercourses and drainage systems are required to be temporarily diverted to

enable the works to be carried out, approval for such diversions shall first be obtained

from the relevant authorities. The diversion shall be maintained while the work is being

carried out and shall be re-instated, including the removal of any obstruction to

hydrological flow as soon as practicable after work is completed.

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No excavated material or debris shall be permitted to enter existing drainage systems or

water courses. Settling ponds or other approved means shall be provided, if necessary

to ensure compliance to the requirements of the local authorities.

6.3 Use of Public Access Roads All transportation, construction/installation and surfacing works shall be executed in

such a manner that will ensure that interference with the use of public roads is minimal.

However, if operational safety demands the blockage of public roads, then the site HSE

Coordinator may approve such operation only when temporary traffic control and

diversion arrangements have been provided.

Storage of litter/debris, tools and equipment in public or private roads shall be

prohibited. Contractors shall develop road clearing strategies to ensure that public roads

are kept clear, safe and passable throughout the duration of their job as they will not be

permitted to cause any public nuisance.

6.4 Sacred / Archaeological Sites Agreement shall be made with Contractors and relevant authorities working on site to

clearly demarcate areas of exclusion around existing sites of heritage and cultural value

to the host community. Contractors shall not remove or relocate any of such sites in the

course of project execution without notifying PHCN’s representative who shall make

necessary arrangements and obtain authorization from members of the affected

community before such removal or relocation.

6.5 Hydrological Properties and Drainage Protection Contractors shall ensure that there will be minimal adverse environmental impact on the

drainage pattern of the project area, and that all hydrological characteristics and

qualities will be maintained at its present status or be improved upon.

During excavation, construction/installation works, the Contractors shall where

necessary ensure that the surface water flows on land or swamp areas are controlled

and if necessary channelled into temporary discharge pits. Such pits shall be located,

designed and constructed in a manner that will minimize the potential threat of erosion.

Muddy water and surface run-off from work sites shall be drained into suitable silt traps

before discharge into rivers or creeks. The silt trap shall be of adequate size and

regularly de-silted. Excessive site clearing shall be avoided and exposed surfaces shall

be re-vegetated as soon as practicable to minimize erosion.

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6.6 Pollution Control 6.6.1 Air Pollution In operating equipment, Contractor shall utilize all practical methods and devices

available in order to control, prevent and otherwise minimize atmospheric emissions or

the discharge of air contaminants. Good engine efficiency of equipment and vehicles

shall be adequately maintained. Indiscriminate burning of materials resulting from

clearance from trees, bushes and combustible materials shall also not be permitted.

6.6.2 Water and Soil Pollution Pollution of surface water by wastewater, oil and other lubricants/ liquid wastes shall be

prevented by proper management practices. Drainage and effluent water from the

chemical/fuel storage and processing facilities shall be collected and treated to

approved regulatory requirements of 10ppm oil in water using wastewater treatment

plant to be installed before discharge.

Contractor shall perform all excavation, construction and surfacing activities with

methods that will prevent pollution of the soil media by accidental spills of contaminants,

debris, and other objectionable pollutants. Regular checks shall be conducted on

equipment to minimize minor lube oil and combustible leaks from engines.

Safe distances and buffer zones shall be established between facilities, work sites and

host communities/substation staff to reduce the impact of high noise levels from the

facilities being reinforced or rehabilitated..

6.7 Transport Operations The Contractor shall manage all transport operations in line with the following guidelines

in order to forestall accidents/incidents.

6.7.1 Pre-mobilization of Vehicles All vehicles to be used for transportation of equipment, materials and personnel shall be

pre-mobilized by the site ERSU Manager. The pre-mobilization shall be conducted to

confirm that the vehicles and the drivers have the necessary competence needed for the

journey. It shall also be confirmed during pre-mobilization exercise that a Job Hazard

Analysis (JHA) has been conducted for the trip and that all recommended precautions

(mitigation measures) have been adopted.

30

6.8 Inspection and Maintenance Procedures for Contractor Equipments In order to assist on maintaining the technical integrity of the facilities, a well defined

inspection and maintenance management system will be put in place in order to ensure

compliance with (safety) regulations. Contractor’s maintenance programme shall deal

with establishing the processes to develop and sustain necessary maintenance

procedures. The system shall address identifying and classifying procedures required as

to their impact on operating integrity, controlling deviations from procedures and

updating of procedures to capture lessons learned. It will also address training and

verifying competency for facility specific procedures.

The maintenance system will include plans and procedures for:

Normal maintenance (routine and breakdown maintenance performed by the

maintenance technicians involved in the proposed project.

Preventive maintenance (activities carried out at pre-determined intervals)

Predictive maintenance (as initiated by facility condition monitoring and assessment

Inspection (in accordance with a pre-defined programme and based on statutory and

company requirements)

31

7.0 ENVIRONMENTAL AND SOCIAL MONITORING PLAN

Contractor and the PMT shall strictly operate a monitoring programme that would lead to

sustainable project-environment relationship. This will be strengthened with the

occasional monitoring visits of the ERSU-PMU. The monitoring programme shall

commence from site preparation through implementation to operation stages in order to

keep track of the entire project activities and performance. The programme will provide

information on impacts compared with prediction and by doing so provide advance

warning of any adverse changes in both the ecosystem and socio economic

development.

7.1 The main objectives of the monitoring programme are to: 1. Ensure compliance with regulatory emission and discharge limits

2. Monitor changes in existing physico-chemical, biological and social

characteristics of the environment, compared to both the environmental baseline

and predicted conditions

3. Ensure continual interactions and flow of information between Contractor and the

stakeholders

4. Determine whether any detected changes in socio- economic and environmental

components are caused by the project or by other forces

5. Determine the effectiveness of the control and mitigation/ enhancement

measures and provide basis for recommending additional measures

6. Ensure that the established transparent procedures for carrying out the proposed

project are sustained

7. Ensure sustenance of accountability and a sense of local ownership through out

the project lifecycle.

8. The lessons learnt from the monitoring will be used to further strengthen the

respective teams

The programme is for the initial stages of the project. The monitoring frequency is

subject to review after the first year to determine its effectiveness and possibly include

other identified areas of concern. The ERSU-PMU shall ensure that the monitoring

programme is fully implemented by Regional ERSU and designated State/Federal

Agents.

32

The Environmental monitoring programme designed for the construction and operations

phases of the project is shown in the Table below.

Table 7.1: Environmental Monitoring Programme for the proposed NEGIP

Components Project Phase Impact Indicator

Location Method of monitoring

Duration/ Frequency

Biodiversity (Vegetation and wildlife)

Site preparation and operation/maintenance phases

Abundance and diversity of native plant and animal species, presence of exotic plant species

Survey and sampling within the S/S and access way corridor and within the communities along transmission route

During Site

Preparation and

yearly during

operation phase

Air Quality Site Preparation, Construction/installation and Operation Phases

CO, SOX, NH3, NOX, and HC

Sampling and measurement within the S/S

Weekly during site

preparation and

construction yearly

during operation

phase

Soil Site Preparation, construction/installation and Operation Phases

PCB, HC, Heavy metals, & Hydrocarbon utilizing Fungi and Bacteria

Sampling and testing around the transformer locations and within the switch yard

During Site

Preparation and

Twice yearly during

operation phase

Surface Water

Construction/installation and Operation Phases

pH, Cond., TDS, BOD, PCB, COD, Turbidity, Oil and Grease etc.

Sampling and in-situ testing of water from wells around the S/Ss and streams near the laboratory testing

During

construction/

installation and

yearly during

operation phase

Noise Site preparation construction/installation and operation phases

Noise Level 90 dB (A)

Measurement around Substation and the adjoining host communities

Weekly during site

preparation and

construction yearly

during operation

phase

33

Community health

Site preparation construction/installation and operation phases

Common/prevalent diseases in the S/S & host communities

Collection of data and statistics from Clinics and Hospitals within host communities

Yearly and or when

necessary

Socio-economic indices

All phases Traffic flow, income levels, housing, trading activities, and social infrastructure

Within host communities

Twice yearly during

project phase

Employment pattern

All phases Contractors/suppliers, part/full time Employment, skilled/unskilled labour recruitment

Consultations with community leaders and youths in host communities and review of Employment quota

Yearly during

project phases

Compensations/Homage

All phases Land take, accident victims, landlords/community relationship, leadership and governance

Consultations and review of MOU with host communities

During construction

phase and bi-

annually during

operation/maintena

nce

7.2 Regulatory Compliance Plan

A comprehensive checklist shall be developed in order to check every HSE-related

regulations for the proposed project including those yet to come. The specific

requirements of each of the regulators. Standards or codes shall also be clearly defined

in the checklist. Project-specific compliance shall be interpreted and documented into a

Regulatory Compliance Plan (RCP) which will be approved and then incorporated into

the routine administrative activities.

8.0 WORK SAFETY AND OCCUPATIONAL HEALTH PLAN Operations within the work site shall be subject to government, industry and PHCN

Policies guidelines. All PHCN and Contractor staff shall be well informed and trained on

the HSE policies and guidelines. All facilities shall also be designed to enhance safety

planning, and activities shall be executed within the confines of relevant legislation and

stakeholders interests.

34

PHCN/Contractors shall provide adequate health services as well as site first aid

services for its workforce. The first aid services shall be extended to visiting personnel

and casual workers. All construction activities shall be properly managed through careful

planning and the applicable and relevant HSE policies and inclusive of the following:

8.1 Use of Permit-to-Work Job Hazard Analysis and toolbox meetings

Use of appropriate PPE in designated areas

Prohibition to drinking of alcohol during working hours and at work sites and facilities

Prohibition to night trips

Regular emergency drills

Prohibition to smoking in fire hazards areas

9.0 WASTE MANAGEMENT PLAN The manner in which wastes are handled, stored and disposed is dictated by the nature

of the waste and this waste management plan takes into consideration the nature of all

wastes that will be generated during the lifetime of the proposed project.

The following objectives form the basis for the waste management plan of the project.

Progressive reduction of wastes with the target to minimize overall

emissions/discharges, which have adverse impact on the environment

To meet the environmental requirements of FMENV and other national and international

waste management as well as PHCN corporate waste management guidelines

To establish, implement and maintain waste segregation aimed at enhancing recycling

To ensure that PHCN and Contractors are responsible for effective waste handling and

disposal process, which shall be monitored by relevant waste disposal authorities

To ensure that waste management programme is in line with the provisions of the

Environmental Management Programme of ISO 14001.

The standard for the plan are binding on all staff and Contractors involved in the

proposed project with respect to the:

Emission or release of pollutant and fugitive gases

Discharge or spill of untreated liquid effluent on land and into surface water

Discharge of solid waste on land and into surface water

35

Generation of noise.

9.1 Waste Handling Guidelines For proper handling and disposal, wastes shall be well defined at source and the

definition transmitted along with the wastes to the final disposal points. PHCN and

Contractors personnel shall define and document all wastes generated in the course of

work in a monthly waste stream report, which shall be used to track/monitor wastes

generated from the Substations.

Basic information that must be provided as a minimum for adequate definition of wastes

include:

9.2 Waste type identification; The major categories of wastes envisaged from the Substation Projects are outlined as

follows:

Category/Definition Solid wastes This include felled vegetation/trunks, woods from crates, metals, papers,

printer cartridges and other office services, domestic waste (waste generated from camp

kitchens, packing materials, boxes and plastics)

Liquid wastes This include non hazardous operational waste generated from

work construction sites e.g. lubes, lubricants, sanitary water, paints etc

Gaseous wastes This include combustion products from construction engines,

welding gas, natural gas leaks etc

Hazardous waste is any gaseous, liquid or solid, which due to quantity, physical,

chemical or infectious characteristics have the potential to harm human health,

environment when improperly handled, stored, disposed, transported or treated e.g.

acids, lead, phenols, etc. In this case, the main hazardous waste expected is PCB

because of the age of the Transformers and as such we are likely going to be faced with

the management of PCB in transformer oils in compliance with the UNEP chemical

management handbook, on handling, complete elimination and total phase out of all

these old equipment for Health and safety purposes. For this ESMP, the following are

considered: Determination of the presence of PCBs in soil, equipment or containers of used oil:

36

PCBs oils were initially proposed as dielectric fluids for use in electrical equipment such

as transformer, capacitors, Switch gears, Circuit breakers, Voltage regulator, etc,

because of their excellent dielectric properties and also because of their very low

flammability. PCB oils can absorb rapid changes in electric fields with very little heating

up i.e. very little loss of energy. PCBs have a low flash point and no fire point, meaning

that they are stable in changing temperatures. They burn only if placed in contact with

an open flame. The by products of PCB combustion are very toxic compounds called

dioxins and furans. Apart from the by products, PCB is a very dangerous chemical on its

own because of its great stability and oleophilic nature, meaning that they are easily

absorbed by the fatty tissues of human and animals. PCB can be detected through any

of these major characteristics by checking the flame test and or solubility test:

Measurement of the concentrations of the PCB Oils in equipment/Soil: This can be

done by using Dexil PCB screening kit for the quantity of PCB in part per million of an

equipment/soil in question.

The identification and assessment of PCB contamination in oil, soil, drains and ground water could be done by using the screening kit to get the quantity of PCB in

each sample before they are taken for the actual laboratory analysis. However, it can

also be done though the following simple tests:

a) Density Test: Because of the presence of chlorine which is a fairly heavy

atom; PCB oils generally have high densities.

b) Chlorine Test: this is a simple chemical test for the presence of Chlorine.

What is required normally is a simple test that can be carried out rapidly after sampling

from the suspected transformer/drain or soil. The analysis of these substances is

generally done in a laboratory using various types of chromatography:

• Packed column gas chromatography

• Thin layer liquid chromatography

• High performance liquid chromatography (HPLC)

Equipment procedures and training for staff and/or contractor’s personnel that will handle PCBs, Training on hazardous chemical management and hazardous liquid

and solid wastes management will be organised for the teams working on the project.

Packaging, Storage and transport of PCB contaminated oil, soil, equipment and other materials: An expert is expected to work on this aspect in accordance with focal

point guidelines i.e. Federal Ministry of Environment (FMEnv.) Also the supervising

37

teams should be trained on packaging, disposal, storage procedures and transportation

of hazardous materials in accordance with the Basel Convention guidelines.

Ultimate disposal of PCB contaminated substances: This could be done in safe,

Government-authorized temporary storages, authorized landfill, or through thermal

destruction role of FMEnv in management of PCBs. Every disposal will be done in

accordance with the FMEnv hazardous waste management guide line.

Health and Safety: Handling of PCB contaminated liquids/equipment Operatives handling PCB liquid and contaminated materials must take the following

precautions: a. a). Ensure ventilation in the working area ;

b. b). Wear full protective clothing i.e.

• One-piece chemical resistant suit:

• Chemical resistant gloves;

• Boots, or disposable cover for shoes

• Fully approved face breathing mask, with a positive air flow from

remote air compressor or bottles; and

• A full face mask with replacement canister can be used for low lever

exposure.

The symptoms of PCB exposure are chloacne, eye irritation, drowsiness,

headaches and sore throat. Under no circumstance must any operatives or observers

smoke in the area where PCB is being handled.

Acceptable threshold limit values (TLV’s) are usually not fixed by legislation. However, it

can be cited here for example, the levels recommended by the United Kingdom Health

and Safety Executive:

- For 42% chlorine content (e.g. Arochlor 1242): long term exposure: 1

mg/m3

- For 54% chlorine content (e.g. Aroclor 1254): long term exposure:

0.5mg/m3

In Germany the former Health Office recommended the following:

- Tolerable Daily intake (TDI): 1mg/kg body weight per day

38

Emergencies: should any spillages of PCBs occur, this must be contained with

absorbent material, which would be placed in the steel drums for subsequent approved

disposal. Operatives dealing with spills must take the following first aids precautions:

- If PCBs come in contact with the eyes, immediately irritate eyes with water for at

least 15 minutes and consult your doctor after that.

- If PCBs come in contact with skin, immediately remove any contaminated clothing

and wash affected skin with soap and water.

- If swallowed, wash out mouth several times with clean water, drink water, and

obtain medical attention.

If inhaled, move to a fresh air zone and obtain medical attention

9.3 Waste Minimization / Reduction Waste minimization implies reduction to the greatest extent possible of the volume or

toxicity of waste materials. The four principles of waste minimization process are -

recycle, reduce, reuse and recover, shall be adopted as applicable. The key elements of

the four waste minimization/management principles practices are outlined.

Minimization Definition

Reduce Process modification / design change

Material elimination

Inventory control and management

Material substitution

Improved housekeeping

Reuse Chemical / Oil containers

Reuse waste heat

Recycle / Recover Recycle scrape materials

Recycle paper

Burn waste lubricating oil for energy recovery

Recover oil from tank bottom

Waste Segregation Waste segregation and characterization shall be carried out on wastes that are similar

and may be combined to simplify storage, treatment, recycling and effective

implementation of appropriate waste disposal methods. Wastes shall be segregated,

39

preferably at source into clearly designated bins at strategic locations. Particular

attention shall be given to the work area where a variety of wastes including fast food

packaging shall be generated. The site HSE Coordinator shall be responsible for

maintenance of the waste segregation scheme at the site.

Waste Disposal All debris, spoil materials, and other wastes shall be cleared regularly from the site and

dispose off at approved dump sites operated by designated waste disposal authorities.

Instructions on material safety handling sheet shall be strictly adhered to and shall form

basis for the disposal of wastes related to such products. Wastes in transits shall be

accompanied and tracked by waste disposal notes. The note shall as minimum contain

such information as date of dispatch, description of wastes, waste quantity, container

type, designated disposal site and method, consignee name, means of transport and

confirmation of actual disposal time and date

Waste management audit of facilities shall be carried out in consultation with the HSE

Department of PHCN, and findings shall be properly documented and followed up.

Accommodation, catering services areas and work site shall maintain acceptable

standard of hygiene and good house keeping.

10.0 GENERAL SECURITY PLAN The project team led by the ERSU Manager shall ensure that adequate security

arrangements are made to handle security related incidents effectively. The project

team will identify, evaluate and manage risks to personnel and property arising from

theft, malicious practices, crime, civil disorder or armed conflict.

In addition, each Contractor will be required to prepare a project security plan and

submit to PHCN for review and approval before mobilization to site. The project will also

organize a security workshop to identify, evaluate and recommend contingency plans for

all security risks.

10.1 Journey Management Plan PHCN and Contractor shall follow its journey management procedures strictly. Trips

shall be planned and combined to reduce driving exposures, mandatory use of seat

belts by drivers and passengers in company and Contractors vehicles shall be enforced.

40

All drivers shall attend defensive driving course while night driving (out of town limits)

shall be discouraged.

Each trip/journey to be undertaken during the proposed project shall be managed in

such a manner that will not result to harm to life or property. A journey management

plan specific to each trip shall be produced and submitted to the Site HSE Coordinator

for approval. The details of the journey management plan shall include proposed

mobilization date, mode of transportation, routes, type of cargo as well as the details of

the JHA conducted for the trip. The Site HSE Coordinator may only approve the trip if he

can confirm that all necessary precautions have been taken to forestall transport

accidents/incidents.

10.2 Accident/Incident Management Plan Accidents do not just happen but are caused mainly due to human factors. They result

in pains to the victims and their families, and waste of money and resources and time to

the Company. Consequently, the main priority to PHCN shall be to prevent accidents

during mobilization, construction and operations stages of the proposed projects.

Prevention of workplace accidents during the proposed projects shall be achieved using

the JHA tool and approved work plan/instructions by supervisors.

Consequently, the technical team must conduct JHA for all HSE critical activities and

develop written and explicit work plans/instructions for such operations. The work

instructions shall integrate the recommendations of the JHA. It is only upon submission

of the written work instructions and the supporting JHA document that the Site HSE

Coordinator may consider the project activity for approval. Project activities may only be

approved if the site HSE Coordinator is objectively convinced that the Written Work

Instruction (WWI) are practicable, safe and in accordance with regulatory requirements.

The use of JHA and WWI as work management systems shall include job planning and

permitting, shift / tour handover meetings and logs, special procedures governing higher

risk activities, control of simultaneous activities, energy isolation and workplace

preparation, management controls for temporarily removing safety devices, and

reinstating the facilities and preparing to restart operations. It shall also include

requirements for reviewing completed jobs and capturing and communicating lessons

learned about the work and management system.

41

Accidents shall be reported and investigated to the ERSU Manager in line with PHCN

accident reporting procedure. All personnel shall be encouraged to report all

accidents/incidents and to cooperate in the investigation of such occurrence. Staff shall

be made to know that accidents/incidents investigation are “fact finding” and not “fault

finding” exercises and are particularly useful as lessons in preventing re-occurrence.

10.3 Emergency Response Plan The PMT and Contractors will demonstrate that all potentially significant hazards and

potential impacts of the project activities have been identified, the associated

risks evaluated and understood, and that control and recovery measures to effectively

manage these risks and impacts are in place before mobilization to site. PHCN will

assist Contractors, where necessary, with the provision of a generic hazard list for

guidance.

In case of an emergency, Contractor emergency response procedure will be activated.

Its objectives are:

To ensure no loss of life

To ensure that the environment is protected

To ensure that manpower, equipment and funds are available to effectively contain the

emergency (fire, explosion, electrocution, shocks, accident, spill clean up for

oil/chemical, etc)

In order to ensure that good record keeping is maintained and accurate information

concerning emergency are disseminated to the workers, public and government,

the under mentioned procedures cover the information and issues on the following:

Transformer shut down

Search for leakages

Isolation of supply points

Notification of authorities

Safety precaution and environmental proceedings

Repair methods and procedures

Emergency repairs

Contractor arrangement

Re-commissioning and start up

The PMT and Contractors will identify all potential emergency situations and develop

procedures to use in such scenarios as explosions or fires, hydrocarbon/chemical spills,

weather related disasters, hostage taking, community disturbance, kidnapping, etc.

Emergency drills will be conducted to demonstrate preparedness for response and

42

schedule of drills and testing of emergency instruments will be prepared by

PHCN/Contractors on the proposed projects.

Every technical Contractor on the proposed projects will prepare and submit for

approval contingency plan for emergency situations and possible incidents beyond the

capability of site facilities.

10.4 Consultation Plan This involves soliciting peoples views on proposed actions and engaging them in

dialogue. It is characterized by two way information flow, from project authorities to

people, and from people to project authorities. The overall aim of the consultation plan

for the project therefore is addressing the concerns and opinions of the stakeholders

with the ultimate view to assuring a smooth project implementation.

Consultation about these rehab/reinforcement projects have been initiated by the PMU-

ERSU to Federal Ministry of Environment, the World Bank Safeguard Team, PHCN-

TCN HQ & project sites, surrounding Communities and shall remain a continuous

process during implementation. The programme for the project construction and

operations stages include:

Visits and courtesy calls on community leaders and other stakeholders to discuss the

effectiveness of the addressed social issues on the lives of the host communities.

Direct visit to the affected populations to consider (through questionnaires, interviews

and visual observations.

Organizing large public meetings (participatory rural appraisal- PRA) to discuss public

welfare, clarify misconceptions and address new issues as regards the project.

Holding workshops and extension courses on resource management (using simply

written materials, visual representation, videos and scale models to decode technical

languages) and sensitising local people on the latest impact mitigation techniques.

Organizing public seminars aimed at identifying new ways of rendering socio-economic

assistance for the locals.

Establishing a voluntary participatory programme in the local media, television and

radio) through which NGOs, CBOs and other key stakeholders concerned and the

general public can comment on various aspects of the project and to ensure that all

socio-economic and environmental issues are adequately addressed.

In case of any Grievances, the affected person(s) should come to or write the CEO of

PHCN-TCN and copy the head of Substation who then will attempt to resolve any

43

grievance. He will liaise with the PMT in sorting out the grievance and notify the CEO

PHCN. When the CEO of PHCN-TCN cannot resolve the grievance himself, the

offended can then seek redress from any Court of Law in Nigeria.

10.5 Communication Plan Effective two-way communication between PHCN and Contractor staff on HSE and

security issues will include awareness programmes to motivate staff and Contractors.

HSE and security information experiences will be shared between PHCN and

Contractors to facilitate improvement in HSE and security performance.

Contractor shall ensure its staff involved at all levels in the proposed projects become

familiar with the importance of compliance with the adopted HSE policy, regulatory

compliance plan, security plan and their individual roles and responsibilities in achieving

their compliance.

Each person shall be aware of his respective work activities, inherent job risks and

hazard and their controls, mitigation measures and emergency and response

procedures that have been established. They also need to be aware of potential

consequences of departure from agreed operating procedures. Consequently each

Contractors will have a project communications focal point to enhance communications

with the Contractor project team at various locations. Contractors will set up appropriate

procedures and lines of communication to handle HSE and security issues (e.g. direct

access to the nearest clinic, direct access to emergency services, etc).

Contractors should be able to communicate easily with their base offices, work site and

local PHCN in an emergency situation. Appropriate safety programmes and promotions

need to be employed in order to effectively promote HSE and create awareness e.g.

minutes of meetings, plans and performance targets, HSE performance on news board,

posters, bulletins, video, news flash, e-mail etc.

Appropriate HSE incentive programmes should be established to promote individual

HSE performance improvements e.g. suggestion boxes, personal recognition,

observation of annual safety week, HSE performance bonus schemes etc.

11.0 COMMISSIONING/HAND OVER PLAN

44

The risks associated with the commissioning and handover phase of the Projects will be

adequately evaluated and will be covered by detailed commissioning procedures and

guidelines. The Engineering, Procurement, Installation and Commissioning (EPIC)

contract strategy will allow time for familiarity of the commissioning/operation team. This

will allow for effective supervision and carryover of priority items into the operation

phase. A pre-commissioning audit will be carried by the PMT for the proposed projects.

Specific commissioning plans covering all significant Contractor commissioning

activities, particularly control of potential dangerous operations during the

commissioning will be developed. The proposed facility will not be put into operation

unless commissioning approval is received from PMU and PHCN-TCN.

12.0 DECOMMISSIONING / ABANDONMENT PLAN The design and facilities shall take due recognition of the need to decommission the

Transmission Substation and the ancillary facilities at the end of their operational life,

the abandonment plan shall take due note of the current national and international

legislative requirements.

The following shall be consider at the end of the project lifecycle:

Need for facilities decommissioning and notification to FMENV.

Team shall be set up to study and plan the decommissioning/abandonment programme

in a manner that meets standard requirement.

An Environmental Evaluation Report (EER) to determine if the activities carried out at

the site have caused any detrimental effects and if any, discuss mitigations and

restoration measures.

In-depth Environmental Studies for the actual removal of equipment (demolition) has to

be carried out.

45

ANNEX 1

COST ESTIMATES

Cost Estimate

The table below shows the cost estimate for implementing the various intervention plans

for mitigation, environmental monitoring and ERSU capacity building at the substations.

S/N ACTIVITY INTERVENTION PLAN COST (USD) SUB TOTAL ACTION 1 Mitigation • Site preparations (4 Nos.)

• Construction • Decommissioning • Substation Operations

3,000.00/site 5,000.00/site 2,000.00/site 5,000.00/yr/site

12,000.00 20,000.00

8,000.00 20,000.00

TCN PMU Contractor TCN

2 Environmental and Social Monitoring

• Biodiversity (Vegetation and wildlife)

• Air Quality • Soil • Surface Water • Noise • Community Health • Socio-economics

1,000.00/site 1,000.00 1,500.00 1,000.00 700.00 1,200.00 1,000.00

4,000.00

4,000.00 6,000.00 4,000.00 2,800.00 4,800.00 4,000.00

PMU-ERSU

‘’ ‘’ ‘’ ‘’ ‘’ ‘’

1 ERSU-PMU • Capacity Building o Consultancy on the

‘Development of PCB Clean-up procedure/process.’

o Provision of Soil, Water and Air sampling equipment.

• Training o Environmental

Monitoring & Modelling.

o Environmental Audit o Basic Sampling

Techniques o PCB detection and

Disposal Procedures.

40,000.00

10,000.00

100,000.00

150,000.00

PMU-ERSU

‘’ ‘’ ‘’

2 ERSU - Substations

• Capacity Building o Establishment of an

ERSU for each substation.

o Establishment of an Environmental Committee that will ensure the implementation of environmental Monitoring and Audit reports.

PMU-ERSU PMU-ERSU

46

o Provision of protective wears (Hard hats, safety gloves, Ear Muffs, Nose muffs).

o Provision of Fire Fighting Van and upgrade of other fire fighting facilities.

• Training o Environmental

Monitoring and Modelling.

o Environmental Audit. o Basic Sampling

Techniques o PCB detection and

Disposal Procedures.

70,000.00

200,000.00

100,000.00

270,000. 00 100,000.00

‘’ ‘’

3 FMEnv./NESREA

• Capacity Building o Establishment of a

Database and a website for Environmental Assessment Documents for the Federal Ministry of Environment.

o Provision of basic soil, water and air sampling equipment.

• Training o Water and

Environmental Law and Institutions.

o Environmental Monitoring & Modelling.

o Environmental Audit. o Basic Sampling

Techniques o PCB detection and

Disposal Procedures.

100,000.00 50, 000.00

100, 000.00 50,000.00

PMU-ERSU

‘’ ‘’

Grand Total USD 759,600.00

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ANNEX 2

ENVIRONMENTAL AND SOCIAL SITE-SPECIFIC CONDITIONS AT AKANGBA 330/132/33kV T RANSMISSION SUBSTATION.

The Akangba 330/132/33kV Transmission substation is located between coordinate

points N 0538465 and E 0717990 on an elevation of about 34feet above sea level within

Surulere L.G.A. of Lagos state. This station was commissioned in 1965 to improve

supply in the Surulere area of Lagos. The station has 4 x 90 MVA and 1 x150MVA

power transformers in the 330kV switch yard, 2 x 60MVA power transformers in the

132kV switchyard. All other associated facilities in a typical electric power transmission

station like Switch Gears, Insulators, Isolators Buss Bars etc. are also present in this

station and were commissioned alongside the Transformers about fourty-five years ago.

The facilities at this station are old and have out lived their life spans. More so the

technology applied in the installed equipment is old and have been phased out by the

manufacturers, making it almost impossible to get spares. The fact that the transformers

at this station date to 1965 reveals a real risk of PCB contamination in the event of

Transformer oil spillage.

The substation is littered with scrap materials of different kinds and spare equipment are

also kept in the open. There are evidences of Transformer oil spillage where the drums

of Transformer oil are kept. The waste water tank is also contaminated with oil. The

wastes from the air tanks have a rusty appearance suggesting that the air tanks are

rusted and need to be replaced. Environmental management at this station is generally

poor and this is largely responsible for the oil contamination and scrap found within the

substation premises.

The rehabilitation work to be done at the station will involve the replacement of Isolators,

Circuit breakers and some other ancillary facilities. A new 33kV substation is likely to be

constructed to replace the old indoor unit presently used there. A few more Power

Transformers will also be installed to boost the capacity of the substation since all the

existing Transformers are already overloaded.

48

This ESMP is designed to address the environmental and social impacts that may arise

from the rehabilitation activities at the Akangba 330/132/33kV Transmission substation.

It will also proffer solutions to the lingering environmental issues like oil spillage and

disposal of scrap materials and also put in place a well trained Environment,

Resettlement and Social Unit (ERSU) that will ensure strict compliance with World Bank

and other International environmental standards in the day to day running of the

substation.

Summary of Peculiar Impacts A new 33kV substation will be constructed to replace the old in-door 33kVstation

presently in use at the station. This will involve excavating the soil to cast foundations

for the Transformers and other switch yard equipment thus exposing the soil to erosion.

This also means that the old 33kV switchyard will be abandoned leading to the

generation of a huge pile of wastes and scrap materials. The existing transformers at

this switchyard will also be decommissioned and scraped.

49

Figure A 1: Scrap Materials Littering the Akangba Substation Premises.

Figure A 2: Air-Blast Operated Circuit Breakers on the Indoor 33kV Switchyard.

50

Figure A 3: Decommissioned, oil-filled Reactor at the substation.

Figure A 4: Decommissioned Insulators and other scrap materials at the substation premises.

51

Figure A 5: Drums of transformer Oil at a section of the substation – note the dark patch of oil on the ground. This is a likely source of PCB contamination.

Figure A 6: Waste water drain with oil stain.

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Figure A 7: Rusty stains from an air tank.

Figure A 8: Abandoned vehicles within the substation premises.

53

ANNEX 3

ENVIRONMENTAL AND SOCIAL SITE-SPECIFIC CONDITIONS AT ALAGBON 132/33kV TRANSMISSION SUBSTATION.

The Alagbon 132/33kV Transmission substation is located between coordinate points N

0546645 and E 0714272 on an elevation of just 17 feet above sea level by Dolphin

Estate within Ikoyi area by the Lagos Lagoon. This station was commissioned in 1980 to

boost the supply of electricity to Ikoyi and Victoria Island areas of Lagos and has two 66

MVA power transformers in the 132kV switch yard.

The substation has sunk by at about 1meter and is overgrown with weeds. During the

rainy season it is completely submerged with water, burying cables and making the

substation impassable. The substation staff are able to reach the equipment to carryout

maintenance only by peddling on drums of Transformer oil.

Environmental management at this station is generally poor and this is largely

responsible for the oil contamination and scrap found within the substation premises.

The station also has no ERSU unit to manage environmental issues and ensure

sustainability of its operations. This ESMP is designed to address the environmental and

social impacts that may arise from the rehabilitation activities at the Akangba 132/33kV

Transmission substation environmental problems that have bedevilled this substation

over the years.

Summary of Peculiar Impacts The Alagbon Transmission substation is suffering a major environmental problem which

involves the submergence of the general surroundings of the substation including the

cable trenches. Only the foundation of facilities built on piles are left standing. The

premises have sunk by at least 1meter (See pictures below). This exerts tension on the

cables and subsequently the terminal points at the control equipment.

The switchyard is practically unrecognisable and virtually impassable during the rainy

season. This posses very high health and safety risks to the substation staff that are

burdened with the duty of ensuing that the substation up and running, being the only

source of supply to Victoria Island and Ikoyi areas of Lagos.

54

The rehabilitation of the Alagbon Transmission substation will involve the complete

reconstruction of the substation facilities. This will involve diverting supply from this

substation. An alternative source of supply will have to be provided for the areas being

covered by this substation while rehabilitation work is going on. The entire drainage

system will need to be reconstructed to keep the substation dry. This will involve

encroaching on the lagoon, thus disturbing the natural habitat and the population of

species within it.

It is recommended that the entire structures within this station, including the control

room, be erected on piles to limit the effect of sinking.

Vehicular movement around the dolphin estate is usually heavy on a normal day and the

assistance of the Police and Traffic wardens will be required to ensure minimal

interruption of traffic during movement of equipment in and out of the substation.

Movement of equipment should be limited to the night time when vehicular movement is

lowest and this must be arranged and agreed upon all stakeholders. Adequate

enlightenment of the schedule must be made via local print and electronic media to

enable residents plan their movement.

The Alagbon Transmission substation is situated in a residential area and construction

work must be limited to the day time to reduce the impact of noise.

55

Figure B 1: A general view of the Alagbon Transmission substation. Notice the mud cracks of the walkway, an evidence of submergence by water.

Figure B 2: Cable trenches at Alagon TS destroyed due to sinking.

56

Figure B 3: Transformer base exposed due to sinking – notice the clearance between the Transformer plinth and the cable trench. Notice the slanting Transformer base this could be an evidence of shifting of the structures holding the transformer base.

57

Figure B 4: Cables sagging due to a collapse of the supporting cable trench. Notice the exposure of the foundation of the control room.

Figure B 5: Oil stains from a rusted Transformer oil drum.

58

Figure B 6: A clear view of the submergence of the surroundings of the substation premises.

Figure B 7: Scrap materials littering the substation premises.

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ANNEX 4

ENVIRONMENTAL AND SOCIAL SITE-SPECIFIC CONDITIONS AT IKEJA WEST TRANSMISSION SUBSTATION.

The Ikeja West 330/132/33kV Transmission substation is located between coordinate

points N 0527520 and E 0729918 on an elevation of 120 feet above sea level in Ayobo

area of Alimosho Local Government Area of Lagos state. This station was

commissioned in 1979 and supplies Ikeja areas of Lagos as well as Ota, Papalanto and

Abeokuta in Ogun State.

No major turn around maintenance has been carried out since the station was

commissioned about thirty years ago. The technology applied in major equipment at this

station, like in most TCN substations, is old and most have been phased out by the

manufacturers. There is also the risk of PCB contamination in the event of oil spillage

since the transformers are old.

This substation is also littered with scrap materials of different kinds and spare

equipment are also kept in the open sine there is no scrap yard or spare yard to store

old and spare items.

There are evidences of Transformer oil spillage where the drums of Transformer oil are

kept and environmental management at this station is generally poor since there is no

ESRU established to manage environmental and social issues in the daily operations of

the substation.

The rehabilitation work to be done at the station will involve the installation of additional

transformers to relief the existing ones. This substation is fenced with concrete

perimeter walls and no land take will be involved neither will there be any issues of

cultural property.

This ESMP is designed to address the environmental and social impacts that may arise

from the rehabilitation activities at the Ikeja West Transmission substation and as well

establish an ERSU within the substation to ensure compliance with international and

local environmental regulations. The ERSU of this substation will supervise subsequent

60

environmental audits of the substation and implement the reports of same at the close of

the rehabilitation project.

The details of responsibilities of all parties are spelt out in the Institutional Arrangement

chapter of this document.

61

Figure C 1: A general view of the Ikeja West Transmission substation.

Figure C 2: Scrap materials and spare equipment.

62

Figure C 3: Another scene of scrap and spare material lying in the open.

63

ANNEX 5

ENVIRONMENTAL AND SOCIAL SITE-SPECIFIC CONDITIONS AT MANDO 330/132/33kV TRANSMISSION SUBSTATION.

The Mando 330/132/33kV Transmission substation is located in the north-west axis of

Kaduna town along the Old Kaduna-Ilorin express road. This station was commissioned

in 1968 with 2Nos. 60 MVA Transformers. An additional 90MVA transformer was added

in 2000. This transformer exploded and was replaced with another 1x90 MVA

transformer. An additional 1x150MVA Transformer was also added about this period.

The Mando Transmission substation takes care of supply to Kaduna metropolis, Kano,

Katsina, Jigawa, parts of Plateau, parts of Bauchi and parts of Niger states.

The station has an environmental team on ground to look into environmental and social

issues but lacks the funds to implement effective environmental management.

The transformers at this station are overloaded and this is mostly responsible for the

explosion of Transformers, circuit breakers and other switchyard facilities.

The 2x60 MVA Transformers installed in 1968 are still in service and are thus a real risk

of PCB contamination should there be Transformer oil spillage.

There are no proper locations for storage of scrap materials. This explains why scrap

materials are left in the open.

A full fledged ERSU will be established, trained and equipped to ensure compliance with

local, national and World Bank environmental and safeguard policies as part of the

implementation of this ESMP. It is recommended that a fire-fighting van be procured for

this station to help provide immediate remedies for incidence of faire outbreaks.

The rehabilitation work to be done at the station will involve the replacement of Isolators,

Circuit breakers and some other ancillary facilities.

64

Summary of Peculiar Impacts A new 33kV substation will be constructed to replace the old in-door 33kVstation

presently in use at the station. This will involve excavating the soil to cast foundations

for the Transformers and other switch yard equipment thus exposing the soil to erosion.

This also means that the old 33kV switchyard will be abandoned leading to the

generation of a huge pile of wastes and scrap materials. The existing transformers at

this switchyard will also be decommissioned and scraped.