OVERVIEW OF IFC'S SCOPE OF REVIEW IFC's view of this project included:A site visit inclusive of the existing operations, the site for the new fertilizer plant and the location of the new jetty;Meetings with Eleme's Financial Director, the Project Head who is also responsible for Environment, Health and Safety, Quality Control and Assurance Manager, Safety Manager, Fire Safety Manager, Human Resources Manager, Training Manager, Security Manager and Medical Doctor. A meeting was also held with community representatives;Review of the respective environmental impact assessments ("EIA") undertaken for the fertilizer project and jetty, various documentation related to the environmental management and occupational health and safety systems, human resources documentation, responses to IFC's environmental and social questionnaire and presentations by the Company on the project and current operations; andReview of a comprehensive Environmental and Social Due Diligence report of the project undertaken on behalf of various lenders, including IFC, by an experienced international consultancy against IFC's Environmental and Social Sustainability Framework and the Equator Principles. PROJECT DESCRIPTION The Indorama Corporation ("Indorama") is an Indonesian based multinational company operating in 19 different countries and a leading manufacturer of petrochemicals and associated downstream products such as polyethylene, polypropylene, polyester fiber, filament, spun yarns and fabrics. In 2006 the Government of Nigeria privatized the Eleme Petrochemicals Company located in Port Harcourt, the capital city of Rivers State. At the time IFC provided an investment to Indorama to acquire a 75% equity stake in the Company which was renamed Indorama Eleme Petrochemicals Limited ("Eleme" or the "Company"). The current shareholding is: the Indorama Group 65%, Nigerian National Petroleum Corporation ("NNPC") 10%, Rivers State Government 10%, Host Communities 7.5%, the Nigerian Federal Government 5%, and Employees 2.5%.IFC is no longer invested in Indorama and is currently considering a $300 million loan to Eleme to support development of a new urea-based fertilizer plant. The current operations are located on a 360 hectare site west of central Port Harcourt. Approximately 50% of the site is developed and thus there is sufficient space to accommodate the new plant. Existing operations on the site include an Olefins Plant that produces 330,000 tons of ethylene and 126,000 tons of propylene annually. The primary feedstock for the Olefins plant is Natural Gas Liquid ("NGL") which is supplied by the Nigerian Agip Oil Company ("NAOC"), a joint venture between Agip and the Nigerian National Petroleum Corporation, via an 84 kilometer pipeline from a gas collection and separation plant (gas plant) located in OBIAFU /OBRIKOM.The ethylene is used in the Polyethylene Plant to produce high and low density polyethylene with a total combined capacity of 320,000 tons per year. Propylene is used in the Polypropylene Plant to manufacture 120,000 tons of polypropylene polymers per year; these are used in the various applications including the production of materials associated with packaging and labeling, textiles and plastics amongst others. The facility also has two nitrogen plants that produces 4,400 Nm3 of nitrogen gas and 10 metric tons ("MT") of liquid nitrogen per day. Power for the facility is generated via two out of four available natural gas turbines with a total power generation capacity of 132 megawatts ("MW") and there are 3 steam turbines for the Olefins Plant.The new fertilizer plant will be located within the confines of the existing site and occupy some 38 hectares. The main project components involve an Ammonia Plant, a Urea Plant and Urea Granulation plant. The Ammonia Plant will produce 2,300 tons of ammonia per day that will be transferred to the Urea Plant, though in the event that the Urea Plant is not operational, the ammonia would be fed to a storage tank. The Urea Plant will produce 4,000 tons of granulated urea which will either be exported via the port or sold in the domestic market. With the exception of natural gas that will be transported to the site via a new pipeline to be constructed, all the utilities required for the operations such as power, air and nitrogen will be supplied via existing on-site facilities.The new gas pipeline for the fertilizer plant will be constructed by Eleme within an existing 15 m Right of Way ("RoW") in which there are currently two existing gas pipelines; both of these traverse the RoW between Eleme and the gas plant at OBIAFU /OBRIKOM. The new gas pipeline will be operated by NAOC to ensure synergy in overall operations of all the three pipelines (the new gas pipeline and two existing pipelines within the same RoW).In addition, a new Port Terminal (jetty) will be built at Onne Port on a plot of land some 6 ha in extent and owned by the Nigerian Port Authority ("NPA"). The land has been leased to Oil Industrial Service Limited ("OIS") for a period of 25 years commencing November 2005, and the lease is renewable for a further 25 years. Eleme and OIS will form a Joint Venture Company (JVC) with a shareholding ratio of 51% retained by Eleme, and 49% by OIS; Eleme will provide the investment for construction of the jetty. The jetty operations will be managed by JVC and will include a quay with a water front measuring 320 m comprised of two berthing sections. Berthing Section-1 will measure 180 m and be suitable for accommodating urea vessels with a length overall ("LOA") of up to 180 meters to serve Eleme. Berthing Section-2 will measure 105 meters and serve OIS; this will be suitable for vessels with a LOA of up to 105 meters and accommodate break bulk, pipes and containerized cargoes. In addition to the quay, there will be terminal infrastructure including all material handling facilities necessary for urea and a urea storage facility with a capacity of 45,000 MT. Other facilities as required for operation of the jetty will include a site office, generators, a control room, parking areas, a weighbridge and fire fighting facilities.The transfer of urea from the fertilizer plant will be by road via an existing road network.Construction of the new fertilizer plant will commence in early 2013 with commissioning in late 2015. The start dates for construction of the jetty and gas pipeline are still to be confirmed, however given the need to be operational once the fertilizer plant is commissioned, construction of the jetty and gas pipeline are expected to commence in 2013. IDENTIFIED APPLICABLE PERFORMANCE STANDARDS PS1: Social and Environmental Assessment and Management SystemPS2: Labor and Working ConditionsPS3: Pollution Prevention and AbatementPS4: Community Health, Safety and SecurityPS5: Land Acquisition and Involuntary ResettlementThe fertilizer plant will be located within the confines of Eleme's existing site on a partially developed section of land. The new gas pipeline will be located within an existing RoW that is some 84 km in extent and a survey has been undertaken of the entire pipeline to identify if any structures or agricultural activities will be impacted. This survey has confirmed that no physical or economic displacement will be required.The land for the jetty is within the confines of the port and is vacant and grassed. In addition, the NPA does not allow fishing activities within the confines of the port thus PS 5 does not apply to this project component. Taking a precautionary approach though as defined in the project Environmental and Social Action Plan ("ESAP"), Eleme are required to comply with PS 5 in the event that there is any physical or economic displacement during construction of the pipeline as a result of circumstances having changed at that time when construction commences.PS 6: Biodiversity Conservation and Sustainable Management of Living Natural Resources will not apply to the fertilizer plant given its location within the confines of the site on land that was previously cleared and leveled. Similarly, it will not apply to the gas pipeline given land occupied by the RoW was historically cleared of any vegetation and NAOC undertake routine clearing of the area. Given the land area to be occupied by ancillary activities associated with the jetty has been previously leveled, this PS will not apply to construction of land-based jetty activities. However, it may apply to the marine environment and further assessment of this issue is required as defined in the project ESAP. No Indigenous People have been identified in the areas influenced by the project's activities and thus PS 7: Indigenous Peoples does not apply; this similarly applies to PS 8: Cultural Heritage as all the areas on which construction is to occur have been previously disturbed. ENVIRONMENTAL AND SOCIAL CATEGORIZATION AND RATIONALE This is Category B project according to IFC's Environmental and Social Review Procedure. The Project is expected to have limited environmental and social impacts that will be site-specific and temporary, and none are expected to be significant. The new plant will be located within the confines of an existing petrochemicals site and the cumulative impacts and risks of operating the new the plant, allied to the existing operations, will not pose significant risk to the surrounding environment or communities. Those risks can be avoided or mitigated by adhering to recognized performance standards, operating procedures, guidelines and design criteria as described in the following sections.Key environmental and social issues relate to; i) ensuring the contractors comply with the environmental and social management system and associated plans for construction including aspects related to occupational health and safety; ii) contractor compliance with Performance Standard 2: Labor and Working Conditions; iii) extension of Eleme's existing Integrated Management System to include the fertilizer plant and jetty operations; iv) ensuring adequate emergency response for all the project components; v) operation of the pipeline in accordance with accepted industry practices and; vi) updating various aspects of the project component EIA's to ensure adequate assessment of specific issues such as noise and dredging. Eleme have robust management systems allied to effective infrastructure and in-house resources to ensure adequate management of project related impacts and specific actions to ensure compliance with IFC's Performance Standards have been defined in the ESAP. KEY ENVIRONMENTAL AND SOCIAL ISSUES AND MITIGATION The Company has presented plans to address the potential environmental and social impacts to ensure that the project will, upon implementation of the specific agreed mitigation measures, comply with policies and standards internal to the Company, applicable national and international laws and regulations, IFC's Performance Standards on Social and Environmental Sustainability and the applicable World Bank Group ("WBG") Environmental, Health and Safety ("EHS") Guidelines. The information about how these potential impacts will be addressed by the project is summarized in the paragraphs that follow, and in the project's ESAP which is disclosed with this document.PS1: Social and Environmental Assessment and Management SystemIn accordance with the national Environmental Impact Assessment (EIA) Decree No. 86 of 1992, an EIA is required for the individual project components including the fertilizer plant, jetty and pipeline. Following completion of the EIA's, these are required to be submitted to the Federal Ministry of Environment ("FMENV") for review and approval the process of which includes a Technical Panel review meeting.Eleme commissioned a local consultant to undertake these EIA's all of which are stand alone assessments. Further, in respect of the Fertilizer Plant, the Environment Division of Forster Wheeler, an international engineering, construction and environmental company provided review and support to this EIA to ensure compliance with IFC's Performance Standards. The EIA's for the fertilizer plant and jetty have been completed and submitted to FMENV and currently it is expected that approval will be received in November 2012. The Technical Panel review meeting for the Fertilizer EIA was completed on 13 October 2012 and provisional clearance is anticipated in October 2012. The Technical Panel review meeting for the Jetty EIA is expected to occur in late October 2012 with provisional clearance provided in mid November 2012.The EIA for the pipeline is underway and it is expected that this EIA will be submitted to FMENV at the end of November 2012. Formal approval of all the EIA's is a requirement as per the ESAP and equally there are various other permits and approvals required prior to the commencement of project construction; the need for the latter will be defined in the investment agreement with Eleme.The EIA for both the fertilizer plant and jetty are considered generally compliant with IFC's Performance Standards and where gaps have been identified, actions have been defined in the project ESAP to address these. Completion of an EIA compliant with IFC's Performance Standards is also required for the gas pipeline as per the ESAP. Once finalized, IFC along with an independent consultant will review this EIA to confirm alignment with IFC's requirements.Public consultation activities have been held as part of the EIA's for the fertilizer plant and the jetty and are also occurring as part of the EIA for the pipeline. Project information was disclosed in advance of all public consultation activities in the form of information leaflets provided in the English language called 'Briefing Documents for Public Forum'. These leaflets stated the aim of the fertilizer plant and jetty, any possible benefits and negative effects of the two projects and an indication of future consultation. Information was also disclosed to local communities through their representatives.In addition to the above, there were public forums and stakeholder interviews. The public forums were meetings in which the project was described and stakeholders were afforded an opportunity to provide their views on the project and ask any questions relating to it. Stakeholders at the public forums included representatives of the King of Eleme, local government, youth leaders, women's leaders and officials of the FME, the Rivers State Ministry of the Environment and the police. The forums and meetings were held in English, and meeting minutes taken. The meeting minutes indicate questions raised by stakeholders were adequately addressed by Eleme. The results of the public forum for the jetty were presented in an article in a local newspaper (Inside Eleme, 16-22 July 2012). Stakeholder comments and concerns on the fertilizer plant have also been reflected and addressed in the EIA for this project.The Fertilizer Plant EIA contains a Guideline for Community / Stakeholder Management that outlines the engineering, procurement and construction ("EPC") contractor and subcontractor's responsibilities for those employed in the construction of the fertilizer plant with regards to community engagement. A Stakeholder Management Plan for the jetty has also been submitted to FMENV along with the EIA. To ensure a coordinated approach to stakeholder engagement, a consolidated Stakeholder Engagement Plan ("SEP") will be compiled for all the project activities (Fertilizer Plant, jetty and pipeline) which defines the requirements of various parties during construction and operations and more specifically the roles of the EPC contractor, the Sponsor, the Community Liaison Officer and Project Advisory Committee ("PAC"); the plan will also define the community grievance mechanism. Construction of the pipeline will be undertaken by Eleme in accordance with IFC's requirements, while operation of the pipeline will managed by NAOC and this will also align with IFC's requirements. The SEP will include activities related to the pipeline operations and equallyDuring construction of the project components the lenders will appoint an independent consultant to review compliance of the project with the lender requirements including the ESAP and this review will also extend to the pipeline.Eleme has constituted a Project Advisory Committee (PAC) to manage stakeholder engagement and project grievances for the entire complex. Contractors working on the fertilizer plant are required to maintain communication through the PAC and this will similarly apply to the EPC contractor and any sub-contractors working on the respective project components. The PAC includes members of the six host communities, the local government council and a representative for the King of Eleme (the head of the council of chiefs made up of leaders of ten clans that are located in the Eleme local government area). The PAC is headed by the Commissioner for Chieftaincy, Community Affairs and Local Government.In 2012 Eleme obtained certification against ISO 14001, an environmental management system, OHSAS 18001, a safety management system and ISO 9001, a quality management system. Certification has been undertaken by the Bureau Veritas and the three systems have been incorporated into an Integrated Management System. The Company has a Project Head who also oversees occupational health and safety, environmental management and fire safety, and there are departmental heads for the individual disciplines that are supported by staff dedicated to the respective departments. The Head of the Environment Department is supported by an Environmental Engineer with staff allocated to waste management and monitoring. Once operational, Eleme will extend the existing Integrated Management System to include the fertilizer plant and the jetty.In accordance with national requirements, the existing Eleme facility has the requisite environmental permits to operate the plant and these include a permit for the waste water treatment plant, polymer incinerator and sludge incinerator respectively.The Fire Department has a staff complement of 24, with 18 qualified firemen; 6 firemen are allocated to each shift. The department has 3 fire engines, an emergency response vehicle, water tender, 2 mobile foam trailers, three multipurpose trucks and a hydraulic lift platform. There is a dedicated emergency response room which includes a visual display of all the manual call points and gas and smoke alarms on site. Since 2006 the facility has experienced on average 7 fires per annum. A site evacuation drill is undertaken annually and there are 3 fire drills every year focusing on differing plants or aspects of operations. All staff and contractors undergo basic fire and emergency response training, and there is job specific fire training including simulation drills and live fire fighting training. Port Harcourt has two fire stations that can provide assistance in the event of an emergency, and there is agreement between Eleme and refineries in the city whereby they will provide assistance if need be, and vice versa.Eleme have commissioned a high level risk assessment for the fertilizer project on certain aspects which assessed various worst case scenarios. In the event of such it has been determined that there will not be impacts on communities. However further assessment is required to ensure adequate management of risks and as defined in the ESAP, hazard and operability ("HAZOP") studies are required at various stages in the project development, along with a pre start-up safety review. In addition, the Company will develop and implement an emergency response plan for the Fertilizer Plant, jetty and pipeline that is integrated into Eleme's existing response plan. These plans will also include community consultation as applicable and relevant measures to warn communities.A risk assessment for the pipeline has been undertaken which defines possible risks to communities, the environment and assets from leaks or explosions associated with the pipeline. The assessment concludes that none of the risks are intolerable and that these risks can be managed with appropriate mitigation measures to improve pipeline safety. During operations, Eleme require NAOC to have developed and implemented an appropriate emergency response plan and this will align with Eleme's emergency response plans; this is defined in the project ESAP.At each plant there is a Health, Safety and Environment ("HSE") Ambassador with a total of 8 HSE committees on the site. These committees meet monthly and every three months there is a meeting of all the HSE Ambassadors and Head of Departments with the meeting chaired by the Technical Director. A detailed monthly HSE and fire report is also compiled that provides information on activities to be undertaken in the forthcoming month, training completed, patients treated in the on-site medical centre, safety statistics, plant level HSE meetings convened, workplace monitoring concluded, ambient air quality and point source emissions monitoring, monitoring results from the waste water treatment plant and findings from any audits undertaken. This report is presented at the monthly HSE meetings and distributed to all the departmental heads and senior management.Eleme has a dedicated training centre with a Training Manager and 3 support staff. A training schedule is defined annually and, on average, 13 training sessions are convened per month. Aside from compulsory HSE courses, every two years all staff are required to attend a training course on fire safety and emergency response. Further, as defined in the human resources documentation, each staff member is required to undertake a minimum of 40 hours of training every 2 years.Overall Eleme has robust environmental and occupational health and safety ("OHS") management systems that are integrated into all operations, and this similarly applies to fire management and emergency response. As defined in the ESAP, Eleme will extend these existing systems to the new Fertilizer Plant and jetty and ensure there are adequate resources to ensure effective implementation.Eleme is currently engaging with two experienced contractors to construct the Fertilizer Plant on an EPC basis. Eleme and Indorama have experienced staff that will provide project oversight and to ensure construction occurs in accordance with the design specifications. For purposes of construction of the Fertilizer Plant, jetty and pipeline Eleme will be required to develop and implement a project specific environmental and social management system ("ESMS") inclusive of OHS. This system will include management plans for the respective project components and define the Company's and EPC contractor's roles and responsibilities relative to implementation and monitoring. While there will be independent review of this ESMS, Eleme, via its existing HSE department, will continually assess implementation of the management system to ensure compliance. In addition, the EPC contractor will be contractually required to comply with the project ESMS. These requirements are set forth in the ESAP. Equally, Eleme will need to comply with the relevant components of the SEP to be developed for this project component.PS2: Labor and Working ConditionsThe Company employs 763 workers of which 161 are expatriates and remaining are from local communities and the total number of women employed is 48. In addition, there are 358 contracted workers who provide services related to catering, security and cleaning amongst others. The minimum age for employment in Nigeria is 18 years and the Company employs no individuals under this age; typically the minimum age is 21 years at Eleme.Eleme has a Human Resources Policy and the associated employment procedures and employment conditions are defined via this documentation. In addition, Eleme has a collective bargaining agreement with the Union of Petroleum and Natural Gas Workers for Senior Staff and there is a similar agreement with the National Union of Petroleum Gas for junior staff. The agreements define the approach to remuneration, policies related to training and medical cover, life insurance, disciplinary procedures, grievance mechanism, leave availability, various benefits provided to workers such as loans, allowances and subsidies along with the retrenchment mechanism. The Company has an Ethics Policy that contains provisions for non-discrimination in hiring, evaluation, promotion, compensation and other employment related decisions. The Company's employment procedures also apply to contractors whom are also unionized. All employees and contractors have a signed letter of employment. Overall the Company's employment conditions comply with this Performance Standard.Approximately 300 permanent employment positions will be created for operation of the Fertilizer Plant and the Company's existing approach to the management of human resources will apply to these individuals. The number of employees required for jetty operations will be approximately 40 and Eleme will extend the existing approach to the management of human resources to them.The number of employment positions during the construction phase is still to be defined, however it is envisaged this could peak at 3,000 workers. The EPC contractor will provide the project management staff and those required for specialized tasks; however the majority of the workers will be employed from the local communities. As defined in the project ESAP, the EPC contractor is required to comply with this Performance Standard.Occupational health and safety is managed via implementation of the OHSAS 18001 management system and Eleme was recently awarded a 5-star with "Sword of Honor" rating by the British Safety Council. The manager of the Safety Department is supported by safety engineers with one engineer available per shift. Each Shift Manager is responsible for safety and they are assisted by a safety representative. There is a comprehensive set of safety procedures and all hot work needs to be approved by the Fire Department. Induction training is undertaken for all staff and contractors, job specific training is undertaken based on a task risk assessment which is completed for all jobs and there are regular tool box talks per shift. The shift foreman is required to ensure workers are appropriately trained for tasks they undertake and the Safety Department undertakes ad hoc audits to confirm compliance. Personal Protective Equipment ("PPE") is made available to workers and contractors alike with the availability based on the task description. The HSE Ambassador is required to ensure workers have the appropriate PPE and the Safety Department assesses the quality of all PPE prior to acquisition. Contractors are required to comply with Eleme's safety requirements and each contractor has a safety representative that reports to the Eleme Safety Manager. In 2006 the Company had no lost time injuries ("LTI") whilst since then there has only been one LTI annually aside from 2010 when there 2, along with 2 fatalities; the latter was as a result of an off-site traffic accident. Minor injuries are also recorded along with near misses and the Company has initiated an incentive scheme to encourage workers to report near misses such that corrective actions can be implemented accordingly.NAOC is accredited against OHSAS 18001 and this system will similarly apply to the new pipeline. As such, the approach to OHS management during this phase is considered consistent with IFC's requirements.Eleme has an on-site medical center equipped to deal with any medical emergency. The center is managed by a doctor and has a total staff complement of 22 individuals which includes another doctor, nurses and paramedics. The center has an ambulance and is in the process of acquiring another. If necessary medical cases may be transferred to government or private hospitals in Port Harcourt. Prior to being appointed all candidates are subject to a full medical examination and undergo annual medical examinations. In addition, there are specific health surveillance programs focused on workers involved in certain tasks, for example those that may be exposed to vibration and radiation. Monthly noise and radiation exposure surveys are also undertaken at predefined points through the site, and the level of volatile organic compounds is assessed. Eleme also provides voluntary testing for HIV/AIDS and free anti-retroviral to workers and contractors.Currently there is on-site accommodation for expatriate staff and all the local staff reside in the surrounding areas. This accommodation complies with IFC's requirements and further accommodation is to be constructed to accommodate additional staff. As per the project ESMS, the EPC contractor will be required to provide expatriate worker accommodation compliant with IFC's requirements and this will be monitored by Eleme. Local workers will be sourced from the local communities and reside outside of the Company's complex.The EPC contractor and associated sub-contractors for the Fertilizer Plant, jetty and pipeline will be required to comply with Eleme's existing OHS system and the approach to OHS by the contractor and sub-contractors alike will defined in the project ESMS.PS3: Pollution Prevention and AbatementThe primary raw material for the Olefin Plant is NGL received via the external pipeline. In addition to ethylene and propylene, other main raw materials used in the production of the polyethylene and polypropylene include catalysts, solvents, and additives. All bulk liquid raw materials and products are stored in above ground bunded storage vessels.The primary source of air emissions from existing operations include; i) the four Gas Turbine exhausts from the power plant; ii) three flares, one from the Olefins Plant, ethylene storage, Oand Polyolefin Plant and other hydrocarbon storage respectively; iii) the two waste oil burning pits; iv) two incinerators, one for burning of the wastewater treatment plant sludge and another for the process solid residues generated as well as the domestic wastes; v) six stacks from Olefin cracker and; vi) three stacks from the furnaces in the Polyethylene Plant. In addition, fugitive emissions from the storage tanks and faulty equipment (i.e., valves, flanges, etc.) are also released. Main pollutants released include SO2 ("sulfur oxides"), NO2 ("nitrous oxides"), VOCs (volatile organic compounds"), CO ("carbon monoxide", PM, ("particulate matter"), and CO2 ("carbon dioxide").Eleme have four on-site ambient air quality monitoring stations and two off-site, one located in the Akpajo community (east of the site) and one in the Aelto community (south of the site). These stations monitor for all the parameters defined above and also include H2S ("hydrogen sulphide") and CxHy ("hydrocarbons"). Ongoing monitoring indicates the results are all well below the national standards and those defined in the WBG EHS Guidelines. Quarterly point source monitoring is undertaken on the polymer incinerator, sludge incinerator, olefins heater stacks, boiler stacks the thermal power plant stacks for SO2, NO2, H2S, CxHy, VOCs, oxygen and carbon dioxide, and the results are all within those as defined in the WBG EHS Guidelines.The EIA undertaken included additional baseline monitoring on-site and within three adjacent communities with the findings confirming the results of the ongoing monitoring by Eleme in that the results were all within national standards and those defined in the WBG EHS Guidelines. Taking into account the potential stack emissions from the reformer and boiler on the Ammonia Plant and the stack emissions from the Urea Granulation Plant along with the existing baseline conditions, the ambient emissions were modeled. The results of this modeling indicate compliance with national standards and those defined in the WBG EHS Guidelines.Relative to ammonia, modeled concentrations are well below Environmental Assessment Levels for the protection of human health as defined in the UK Environment Agency's Horizontal Guidance for Air Emissions. Further, the ammonia concentrations are below the odor threshold as defined by the Occupational Safety and Health Administration, US Department of Labor. An assessment of air quality impacts associated with the jetty indicates these are not considered significant and there are readily available mitigation measure for potential impacts during both the construction and operational phase. During construction of the pipeline impacts on air quality will be managed via implementation of the project specific management plan (e.g., dust suppression,) and impacts during operations are considered insignificant assuming effective site rehabilitation.The noise assessment of the existing operations indicates compliance with national requirements and the WBG EHS Guidelines, however no specific noise study has been undertaken for the Fertilizer Plant. Thus Eleme will undertake a noise impact assessment for the Fertilizer Plant once the plant design has been defined to the extent that will allow for such and mitigation measures defined if need be. In respect of the jetty, current baseline noise levels are within the limits for industrial receptors and generally within the limits for residential receptors. However as with the Fertilizer Plant, no noise impact assessment has been undertaken. Thus once the preliminary design of this facility has been defined, a noise impact assessment will be undertaken and mitigation measures defined if necessary. These actions are referenced in the project ESAP. During construction of the pipeline noise impacts will be managed via the project specific management plan while during operations this is not considered an issue.Electricity for the entire complex is generated via a power plant comprised of four natural gas turbines with a production capacity of 132 MW. Currently the site requires 32 MW and this will increase by approximately 35 MW once the Fertilizer Plant is commissioned. The energy requirements for the jetty will be provided via three 1500 kVA diesel generators. The current CO2 emissions from Eleme is 829,000 MT per year and this will increase to 1,534,000 MT per year when the Fertilizer Plant is operational. The energy requirements for the pipeline will be defined in the EIA for this project, however are considered to be limited.Water for domestic and industrial operations is supplied by six on-site boreholes with consumption estimated at 1,000 m3/hour. Water for consumption as well as process use (i.e., steam generation, cooling,) is treated on-site prior to use. The total water requirement for the Fertilizer Plant will be 750 m3 per hour to be supplied via 5 new boreholes and this water will be filtered and processed via a dedicated water treatment and demineralization plant. Studies have been undertaken to assess the groundwater reserves which indicate they are sufficient and will not further stress the existing aquifers; the Niger Delta region is recognized for a high ground water recharge rate. The water requirements for the jetty are estimated to be 25 m3 per day to be supplied via a borehole. This water will be pretreated in sand filters for use in the fire system and then further filtered for use as potable water. Water requirements associated with the pipeline will be limited to construction and hydrostatic testing prior to use and these requirements will be defined in the project EIA.Waste water treatment for the entire complex is undertaken at a centralized facility. The process includes primary treatment with chemical dosing and flocculation and secondary biological treatment using aerators and a clarifier. On average the plant treats 60 m3 of water per hour and this includes process water and sewerage. The treated water is mixed with storm water prior to discharge to the Okulu River. The waste water quality is monitored on a daily basis for pH, biological demand, chemical oxygen and total suspended solids and the results for these parameters are well within national limits and those defined in the WBG EHS Guidelines. The quantity of waste water to be generated by the fertilizer plant will be approximately 25 m3 per hour. That related to the Ammonia Plant will include contaminated de-oiled water and waste water from the chemical drain around the boiler. Waste water from the Urea Plant will include de-oiled water and water from the chemical drains and floor washings generated on a periodic basis. Waste water such as condensate will be reused and floor washings from the urea granulation area will be recovered. Waste water not reused or recovered in both plants will be discharged via the waste water treatment plant to the Okulu stream. As noted this water is currently in compliance with Nigerian requirements and the WBG EHS Guidelines and these standards will similarly apply once the Fertilizer Plant is operational.Waste water from the jetty operations will include sanitary and grey water along with wash water and storm water run-off. The intention is to collect this water and treat it with bio-mass reactor technology prior to discharge. This water will also be monitored to ensure the quality is in accordance with the applicable requirements. Once operational, there will be no waste water associated with the pipeline.The entire Eleme site has a well-defined storm water collection system with open lined channels traversing the site and storm water is monitored on a daily basis. All storm water is discharged via the retention pond for the waste treatment plant and this will similarly apply for the new Fertilizer Plant. Storm water from the jetty will be collected via an on-site system prior to discharge into the adjacent port.A Waste Management Plan ("WMP") has been compiled for the existing operations and a waste disposal inventory is submitted to the authorities on a quarterly basis. The main solid wastes include domestic waste, metal and wood scrap, empty drums, sludge from the waste water treatment works, waste oils, oily sludge, alumina dust, ash from incinerators and medical waste. Domestic waste is disposed of at a Government approved waste site in Port Harcourt, spent alumina is stored on-site, waste oils, scrap metal and wood along with the used oils and empty drums are sold, oily sludge is incinerated along with the medical waste and sludge, and ash is stored in a plastic underground tank. Hazardous waste to be generated by the Fertilizer Plant has been defined in the project EIA along with disposal methods. The existing WMP will be strengthened to incorporate waste from the Fertilizer Plant. A WMP has been defined in the EIA for the jetty and determines the wastes generated and the associated disposal methods. Waste management requirements during operation of the pipeline are considered insignificant.Dredging is required for construction of the jetty with the total volume estimated at 150,000 m3. The EIA for the jetty however does not assess the potential impacts of dredging which relate to the release of potential contamination in the dredged sediments along with increased sediments in the water column both of which could have ecological impacts. Thus as defined in the ESAP, Eleme will compile and implement a Dredging Management Plan inclusive of a baseline assessment of sediment properties, the identification of sensitive ecological sites, dredging methods to be deployed to mitigate potential impacts identified and the methods of disposal for the dredged materials.PS4: Community Health, Safety and SecurityOn the eastern boundary of Eleme's site there is residential development which is some 800 m from the production plants on-site. This area is occupied primarily by workers employed by the Company and further in this direction is the city of Port Harcourt. To the north the closet community is located some 1.8 km from the site's fence line while to the south the community is 1 km from the site's fence line, however 2.5 km from the site's production facilities. To the east the closest community is located 5 km from the site's fence line.Road access to the site is on well-maintained roads, however they traverse established commercial areas. The site operates on a 24 hour basis and is continually accessed by cars, trucks and buses transporting workers. Approximately 70% of the Company's product is collected by customers with the remaining being delivered by contractors. In addition to Company vehicles, Eleme also have a fleet of buses that provide transport to workers with this function contracted to an external party. All drivers whether in the employ of Eleme or contractors are required to undergo defensive driving courses and there is a defined speed limit on-site that is strictly enforced by the security department along with traffic calming measures in key areas. All vehicles accessing the site are also vetted by security to confirm their roadworthiness.Traffic related impacts during construction and operation of the Fertilizer Plant and jetty have been defined and a Traffic Management Plan ("TMP") compiled inclusive of mitigation measures. However, additional detail is required on mitigation measures related to the jetty operations and the TMP will be updated to reflect these. All marine navigational operations are managed by the NPA and hence all aspects related to the movement of ships is under their control.As previously defined, Eleme has a comprehensive approach to emergency response which will be further updated to include the Fertilizer Plant, jetty and pipeline. Further, NAOC's emergency response plan for the pipeline will be aligned with that of Eleme's.Security at the facility is maintained via security guards employed by Eleme and the police. The security guards employed by the Company are unarmed and recommended by local community leaders and a full screening is undertaken for any criminal records. The majority of security guards are local residents which reduces the risk of conflict between the security guards and the local communities. The police have a unit stationed full-time at the site that provide armed security and also provide armed escorts when road travel is required by expatriate staff beyond the site or when workers need to access areas off-site where security may be a concern.Eleme's Security Department prepares a monthly report on health and safety that includes statistics on any instances of security safety violations and conflict between security staff and local communities; to date no such instances have been reported. Security at the jetty will be provided via the security guards employed by the Company that have already been trained, screened and recommended by local community leaders.Security requirements by the respective EPC contractors will be defined by the contractors and Eleme's security department will provide input as necessary.PS5: Land Acquisition and Involuntary ResettlementNo additional land take is required for the new production facilities, jetty or pipeline. As noted the survey of the pipeline RoW indicates no physical or economic displacement will be required during construction of the pipeline. While encroachment on the pipeline RoW is prohibited, the ESAP defines the need for compliance with this Performance Standard in the event that circumstances have changed at the time of construction.PS6: Biodiversity Conservation and Sustainable Management of Living Natural ResourcesAs noted there are no issues related to biodiversity with the development of the new Fertilizer Plant or pipeline. However, the jetty EIA provides insufficient detail on the baseline marine environment and thus it is not feasible to assess potential impacts on marine ecology. Thus further assessment of the baseline marine environment will be undertaken to inform the Dredging Management Plan and this will also define mitigation measures during construction of the jetty if necessary

ACCOUNTABILITY MECHANISM OF IFC The Compliance Advisor Ombudsman (CAO) is the independent complaint mechanism and fact-finding body for people who believe they are likely to be, or have been, adversely affected by an IFC or MIGA- financed project. If you submit a complaint to the CAO, they may assist you in resolving a dispute with the company and/or investigate to assess whether the IFC is following its own policies and procedures for preventing harm to people or the environment. If you want to submit a complaint electronically, you can email the CAO at CAO@worldbankgroup.org. You can learn more about the CAO and how to file a complaint at http://www.cao-ombudsman.org/