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Rehabilitation of the Liberia Refinery Company
EIA
Proposed recommendation
Environmental Impact Assessment for the
Proposed/approved rehabilitation of the LPRC.
July 2015
RECOMMENDED REPORT
Prepared by: ANSUMANA E.M. DUKULY, JR.
1.1 INTRODUCTION
The primary petroleum product storage tanks area in Liberia is the Liberia Petroleum Refinery
Company. This area is located in the southcenterrnmost part of the west of Monrovia, specifically
Bushrod Island. The Liberia Refinery Company stretches from NPA of Liberia and as far as to Clara
town, in the West. Although varying in width, it is approximately 3.2 km wide, extending in some
areas into the National Port Authority (NPA). The Government of Liberia (GoL) has divided the
Freeport of Monrovia (NPA) into three PST areas. Liberia Petroleum Refinery Company is located
towards the west extremity of the NPA and is covered by LPRC and SRIMEX & ECOFUEL joint
venture. LPRC holds interests in developing and expanding the PST.
1.2 APPROACH AND METHODOLOGY
The purpose of the EIA is to provide relevant, understandable and objective information to
inform decisions regarding the authorization and expansion of the Rehabilitation of the
Liberia Refinery Company EIA (RELPRC) in Monrovia, Liberia.
This EIA consists of the following four phases:
Screening;
Scoping;
Specialist Studies; and Integration and Assessment.
Screening
Based on limited capacities the initial screening phase identified that a full EIA was
required as petroleum facilities engineering and production have classified as a Category III
activity in terms of the Environmental Impact Assessment Regulations (1998) promulgated
under the National Environment Act of 2003 which was amended in 2010 of Liberia.
Scoping
The second phase of the EIA process was Scoping. The objectives of Scoping were the
following:
1. to identify issues of serious environmental concern;
2. ensure all potential impacts, key issues and reasonable alternatives are identified; and
3. Ensure informed, transparent and accountable decision-making by the Environment
Protection Agency/Authority (EPA).
As part of the scoping phase, a consultation process was conducted manually with an
opportunity to raise concerns and comment on the potential impacts and merits of RELPRC
development. Input was captured in order to focus the assessment on key concerns, and to
better understand expectations of those potentially affected. Figure 1.2 identifies the key
identified during consultation.
Figure 1.2 Key Stakeholder Groups
Project participants (Liberia Petroleum and Refinery Company management and
employees)
Local community members
Vulnerable groups (e.g. general residents)
Local businesses around the LPRC’s Facility
National and level authority especially EPA with references from their achieves
Locals and
Local environment and social NGOs Media groups
A range of issues were raised during consultation. The main issues include the following:
Present Site location and its environmental effects – Some business people and locals
around LPRC mentioned that site alternatives needed to clearly outline both the positive
and negative impacts of the RELPRC. Numerous locals including LPRC’s employees
indicated their preference for the RELPRC to be located outside Bushrod Island because of
serious environmental issues raised as will be explained later.
Awareness Raising and Community Liaison - Many locals and national agencies feel that
LPRC should play a more active role in raising awareness about the project specifically and
oil storage tanks in general and especially for example the Ganta Storage Tank Terminal.
Locals and residents here had been confused because of a number of misperceptions
amongst them that could easily have been clarified if LPRC has had the time to adequately
inform locals especially in nimba and had a proactive community liaison strategy. As the
stakeholders in nimba have requested that LPRC improve their community liaison
capabilities not withstanding this has some political configuration and lobbying effects.
Fish and Fishing – The majority of fishermen around Du River, especially West Point
raised concerns about the impact on the numbers of fish during and since the operation
phase of LPR C commenced. The impact of the current ban on night fishing was also
raised as a concern since it was felt that it may have severe consequences on the local
fishing economy and affect peoples’ income and livelihoods
.
Waste Management -A number of serious observations were made in LPRC’s Tanks Farm
and the kind of waste that the RELPRC is going to generate and how that waste was going
to be handled or disposed is of major environmental concern. LPRC, beyond all
environmental reasons is one of the most polluters of the city as far as environmental
analyses are concern.
Oil Spills and leakages – resident will want to know if LPRC had any management measures
in place that would address clean-ups of oil spills. The impact of oil spills on fish stocks
and water resources was also a significant concern to local stakeholders.
Air Quality – locals and employees are extremely concerned about the impact of the RELPRC
and the aftermath especially operational periods on air quality, during
flaring/flushing/dewatering of tanks. Employees and locals also wanted to know what
measures RELPRC would put in place to mitigate air pollution and greenhouse gases.
Flushing and dewatering - Given the sensitivity of the environment in the project area and the dry
conditions during half of the year, locals were concerned about the risks of fire and potentially
other risks associated with Flushing and dewatering that could threaten the environment.
Community benefits – An overwhelming number of residents expressed the view that the project
should ensure that the local people experience social transformation and that they must directly
benefit from the project. For example many of the locals were anticipating electricity provision
to the whole of Bushrod Island since the hydropower is not operational.
Other issues raised included issues surrounding: project life span, the need for a Strategic
Environmental Assessment, community benefits, security and conflict, and perceptions of
corruption (everyone’s concern).
Other issues raised included issues surrounding: project life span, the need for a Strategic
Environmental Assessment, community benefits, security and conflict, and perceptions of
corruption (everyone’s concern).
Specialist Studies
Specialist studies included baseline information gathering relating to the affected environment
and an assessment of the impacts associated with the proposed development. In support of the
EIA, the following specialist studies were undertaken:
Visual;
Air quality;
Waste management;
Ground and surface water;
Flora and fauna; and
Socio-economic
Integration and Assessment
A synthesis of the baseline information and impact assessment undertaken, which addresses the
key issues identified during the scoping process, is integrated into the Environmental Impact
Statement. Potential impacts are assessed according to predefined assessment criteria and
mitigation measures developed for the impacts.
1.3 LEGAL AND POLICY FRAMEWORK
Liberia has a wide array of legislation that promotes the protection of the environment. A number of
Policies, Acts and Regulations were taken into account during the EIA process though the EPA,
implementer arm of the processes is weak.
An Environmental Impact Study (EIS) has been compiled as part of the EIA process in accordance with
the regulatory requirements stipulated in the EIA
Regulations, 2003 promulgated under the National Environment Act of 2010.
1.4 PROJECT DESCRIPTION
Rehabilitation and Expansion of Liberia Petroleum Refinery Company; Product Storage Terminal
(RELPRC/PST) will consist of the following:
Supply Pipelines from the Jetty to the tank farm three new pipelines (8, 10 and 12 inch diameter) are to
be installed along the onshore Jetty walkway to the product terminal replacing existing pipelines.
LPRC Product Storage Terminal is comprising two adjoining tank fields namely: Mobile and Texaco
with a total Storage capacity of 480 thousand barrels including 15 existing storage tanks:
a) Storage Tanks
The new storage tanks construction shall include shells, floors, roofs, foundations, access stairways,
railings and handrails, together with venting and gauging mechanisms.
b) Piping Network
The new piping network shall include valves, flanges, fittings and pipe support, designed to provide
full transfer flexibility from the pump station to each product storage tank and to the loading station.
Loading Rack and Pumping
a) Tank truck loading
To undertake the complete redesign and build a new loading and pumping facilities with increased
loading capacity. To install top loading with provision for bottom loading. To include essential
components, including meters, loading arm, separators and filters. To install a new concrete pad for
the loading rack, accompany trenches to recover accidental spills.
b) Loading Arm Pumping Station
To install all loading and transfer pumps on one concrete pad large enough for future pumping
capacity, including additional pumps to meet projected demand.
Environmental Protection
a) Prevention actions
To provide environmental protection facilities and procedures to include the prevention and full
recovery of accidental spills and contaminated surface waters originating from the storage tank slab,
pump stations and truck loading areas, which have to be directed to an adequately- sized API oil
separator. To install floating pads on gasoline tanks to reduce air pollution, but also to reduce
gasoline tank breathing losses.
b) Remediation
To conduct an environmental audit to establish the nature and the extent of soil and /or water
contamination and identify the extent of remediation required.
Fire Protection
a) A totally new Fire Water distribution network has to be devised and installed
b) Install all new foam making equipment (chambers)
Power Generation
The contractor shall carried out a thorough and full assessment of the existing electric system and
will provide a report in the context of immediate modifications which may be required for adaption
with the PST project and to install new power generation system to meet demand.
Security
To install adequate security lighting, strategically located inside and around the Tank field perimeter
of meters and along the shore supply pipelines
Safety
To verify and correct non conformities in the actual layout of Tanks within the terminal, taking into
consideration specified regulatory safe distances between tanks as per their respective dimensions,
distances loading racks and property limits, public roads, fire protection equipment, laboratory,
railroads, together with adjacent lodgings and office buildings, all according to applicable local or
international regulations
CRITIQUE OF THE PROJECT FLOW
A) Storage Tanks
If we looked at the general integrity of all the tanks owned by LPRC, it seems pretty well stable to cut
down costs attached. However, there is going to be some technical demands well certain from the
engineering team of LPRC. INTEGRITY of tanks one (1), three (3), five (5), six (6), seven (7), eight
(8), four hundred and three (403), four hundred and four (404), four hundred and seven (407), and
finally four hundred and eight (408) worth a lot to explain.
As a result of serious environmental hazards resulting from reservoir failures there is need to carryout
Periodic monitoring of the reservoir. Above surface vertical cylindrical reservoir used in Oil and gas
industries are constructed of steel and over the years many of the structures have corroded and leaked
petroleum products into the soils thus contaminating ground water and the environment.
Leaking reservoir can be a source of groundwater problem as the petroleum which they carry contains
toxic compounds including benzene, toluene, xylene and ethylene dibromide. These compounds are
thought to cause cancer, and pose a number of health risks including nervous system damage,
reproductive problem and immune system depression. The soils and geological condition at the structure
locations can also affect ground water contamination.
OIL STORAGE TANKS AT THE LPRC TERMINAL
Reservoirs/tanks at the LPRC terminal were constructed between 1956 and 1970s. There are at the
Moment 15 oil storage reservoir, the shortest in height is around approximately 13m in height and
diameter 36.5m while longest is 17.1m in height 31m in diameter.
The structural integrity of these reservoirs/tanks has been of major concern to both local community and
Environmentalists. Although API Standards have not remained the industry standard relative to reservoir
inspection and maintenance, the frequency of testing and inspection can also be affected by various state
and local regulations.
The schedule of this inspection process depend on a number of factors which include: the age, their
Proximity to groundwater, the leak records, the date of the last integrity test, the construction material
used, the product stored, soil condition etc.
Reservoir at LPRC farm is half way bounded with a bound walls which measuring 250m by 150m and at
a height of 12m. The bound walls are to accommodate and contain any spill that may result from failure
of any of the reservoir.
STRUCTURAL HEALTH MONITORING
Reservoir/tanks used by oil LPRC are cylindrical in shape. As a result of age, non-uniform settlement of
the foundation, geological conditions loading and offloading, war, abandonment, negligent, non-
technical team over the years, oil temperature, primary and secondary settlement of sediments results in
radial deformation or out of roundness of the reservoir. This results in the binding of the floating roof or
in cone-roof tanks displacement. Out of roundness may result in the upper shell course buckling. Shell
out of roundness may result in gaps between reservoir shell and their hydrocarbon emission into the
environment occurred. As a safety measure, each reservoir needs to be monitored periodically
TANK 1
This tank has a capacity of approximately 3400000 US Gallons, not neglecting other causes attached,
and based on the observation of the tank, it seems likely that this tank can be revamped using API 510
standards and it will maintain its stability status as before, hence bringing cost reduction (CAPEX), this
will be explained in subsequent paper presentations.
It is advisable to use API 510 by removing the base-floor and adjusting the already tilted ankles and
circumference and or reassessing the tank before management final decisions are taken.
TANK 3
This tank has a capacity of approximately 2600000 US Gallons, the tanks has been quantified if not
replaced, however, based on best practices it seems not completed as sprinklers/terminal cooling system
are not yet up to date, but almost.
TANK 4
This tank has a capacity of approximately 2500000 US Gallons. The floating roof system is good and
based on standards many business people will want to go for it but when it comes to integrity and
stability, the cone roof or fixed roof is always better than it. Others might want to argue about product
losses etc. but no matter what however, no tank is “product lose free” therefore ten it is 100% advisable
to build fixed cone roof.
TANK 5
This tank has a capacity of approximately 1300000 US Gallons. Looking at the tank’s conditions, we
first assume that it is old or outdated, but this doesn’t mean that API 510 cannot be applied or
implemented. Please cut down cost and improve stability. The department of petroleum at LPRC will
give you much needed briefings.
TANKS 6, 7, 8,403,404,407,408
This tank has a capacity of approximately 1300000, 700000, 430000, 660000, 418000, 410000 US
Gallons respectively.
Similarly all other API applications and standards should be applied to avoid unnecessary wasteful costs
not neglecting API 510.
PIPING SYSTEM
Installing an outer pipe around an inner pipe has been found to prevent the release of hazardous
liquids being transported in the inner pipe. This system as a whole is called a secondary contained
piping system, or double-walled pipe. A major use for these systems is for transporting liquid fuel,
“Liquid Fuel Storage and Dispensing Systems.” There are no generally recognized codes for
dimensions.
The interior pipe transporting the liquid is called the carrier or primary pipe. The outer pipe around
the carrier pipe is called the containment pipe or secondary containment. A detail of a typical double-
contained pipe is schematically an illustration to be done by LPRC’s Petroleum Engineers. The two
pipes are to be kept apart by spacers, these are often called frogs or spiders by manufacturers.
Double-wall systems are manufactured from many different piping materials. There is no requirement
for the primary and secondary pipe to be made of the same material, except where a possible
incompatibility may exist. the LPRC piping system is been one of the most vulnerable ever,
therefore, then it is highly recommended to consider all pipes being buried underground to control
fire security, spillages as well as environmental sensibility .
REMEDIATION AND SECURITY
Watering and water system will not be meant only for tanks, if we looked at the roofs of the pump
house, and the loading rack, you will understand that there is a need if not a serious one to cane the
roof as from zinc to clay, the distance of the loading rack should be at least 120 ft. away from offices,
a firefighting sprinkler should be installed within the roof of the loading racks as well as all offices
within the LPRC vicinity because wit fire nothing is ever safe, therefore safety first. The contingency
pipeline line, if it is meant for the future then should be halted and brought within the NPA fence
instead of its present location, because 15 to 25years from now the tiding will be different.
1.5 SITE SELECTION
As part of the EIA process, a site selection study was undertaken from June – July 2015 in
order to identify the most appropriate area for the RELPRC/PST. Hence the old site is
considered as fairly suitable but not advisable for the future because of cluster impedance and
population of the environment as For oil escarpment, that could result in an unacceptable
environmental impact, RELPRC/PST would also result in an additional US$ 30 million capex
(capital expenditures) and US$ 3.3 million opex (operational expenditures) affecting the
financial viability of the Project summing up to $33.3 million tis estimate is an approximation
based on qualitative analyses (quick look). Tis estimate can be reduced to $12 million to $15
million if considerations are given to API 510
Based on such a result, LPRC’s preference will be considered for the following reasons:
Reduced capital expenditure (capex) and operational expenditure (opex) – this is seen as a
serious consideration affecting decision making with the members of the board, as the
additional costs associated would make the financial viability of the RELPRC/PST unfeasible;
Greater energy efficiency and hence lower fuel consumption;
Lower technical risk – e.g. no flow assurance or seismic damage risks associated with a
pipeline up the escarpment because the seismic zone in which Liberia falls is approximately 1
at the magnitude level; and
Lower security risk - security can be better controlled with numerous locations close to the
RELPRC/PST site, as such, Site formed the focus of the RELPRC/PST EIA.
1.6 Social
The population of the Bushrod Island is settled at 6 relatively small landing sites and 1 fishing
location at West Point along the shore. The overall population of the Island is relatively high
although it has increased with time as a result of the improved peace initiatives of the United
Nations and ECOWAS, the attraction of fishing and people coming to the West Point even
from neighboring in search of self-employment from Senegal and Ghana. There has been
considerable population growth over the past few years, with rapid growth expected to
continue.
Education levels are still very low in the republic, with respondents commenting that the value
of education is not fully understood. The population living in the island are predominantly
semi-illiterate, with literacy rates estimated to be approximately 40 percent and as low as 15
percent amongst the women. Poor education levels have also been attributed to parents taking
their children out of school and in facts as a result of accelerated Ebola virus in the sub region
of Mano River, to assist with fishing and other household responsibilities. With these problems
prevailing every day, LPRC will need to provide more scholarships for students at all level
both international and national.
It was reported that the common diseases within the island include malaria (including cerebral
malaria), dysentery, diarrhea, cholera, sexually transmitted diseases (STDs), meningitis,
maternal mortality and anemia in children. Headaches and coughs were also reported to be a
persistent problem most of which are associated with pollution in other ways.
1.7 SUMMARY OF ACTUAL AND RESIDUAL IMPACTS
1.7.1 Nature of Impacts
A key element of ongoing environmental and socio-economic management is to address
uncertainty, through collecting information, additional assessment and, where necessary, the
development of further mitigation and management measures.
As the project moves forward and on-the-ground implementation confirms or puts in to
question the nature or extent of impacts discussed below, these will need to be addressed as
part of the ongoing updating and refining of the Environmental Management Plan (EMP).
It is vital to stress that the residual impact significance ratings provided in this
EIA are based on LPRC’s bending adherence to the mitigation measures (actions) and
ineffective implementation of the monitoring measures. Without this level of commitment from
LPRC, the residual impacts will be more significant than currently assessed.
1.7.2 Summary of Actual and Residual Physical and Biological Environment
Impacts during Construction Phase
During the construction phase, only the impact on local fauna necessitates a medium negative
residual impact. Although the remaining physical impacts received a residual impact of either
low negative or negligible negative, the biggest impact will be on waste, spills, fauna and flora.
During the construction phase of the Project, the activities to be carried out will involve site
clearance for the separator of produced water and temporary and permanent accommodation
facilities, excavation of flow lines trenches, construction of roads in RELPRC/PST area etc.
This will entail flora clearance and thus disturbance of the local flora and fauna and potential
habitat degradation, destruction or fragmentation thus affecting biodiversity. The main habitat
to be impacted will be the snakes with a loss of approximately 0.08 percent of the entire
facility.
A summary of the physical and biological environment impacts including pre-mitigation and
residual impact during construction are summarized below in Table 1.1.
Table 1.1 Summary of Actual and Residual Physical and Biological Environment Impacts
During Construction
1.7.3 Summary of Actual and Residual Physical and Biological Environment
Impacts during Operation Phase
Although no impacts will be received as a residual impact rating of medium negative or higher
during the operation phase, some discussion on the impacts to air quality and flora is pertinent.
While the air quality dispersion modelling undertaken during the baseline studies provided a
worst case scenario and some uncertainties exist as a result of the lack of measured
meteorological data, exceedances in the NO2 1-hour WHO ambient air quality guideline in the
Bushrod Island are predicted. While these exceedances are unlikely to have any health impact
on local communities as a result of the RELPRC, should the facility be expanded or should
other polluting industries be attracted to the area, the cumulative impact could be of concern.
As such, it is imperative that detailed monitoring of ambient air quality be continued while
monitoring of meteorological data also continued so as to generate a long term data set, LPRC
petroleum Engineers will take care of that. It is therefore assumed that a combination of
technology options, engineering design and siting have achieved the desired effect in the
ambient environment, i.e. a reduction in the predicted exceedances of the WHO 1-hour
guideline for NO2 during normal operating conditions.
The operational phase will not have the same severity of impact as the construction phase for
fauna and flora, as over time, most animals (snakes and insects as well as fish) will adjust to
the increased disruption within the life cycle of animals and human habitats on the Island
which are critical habitats, hence decreasing the level of protection from further disturbance.
It is therefore essential that LPRC work in close cooperation with EPA and the existing
concessionaire in terms of ensuring that the conservation worthiness of these habitats is
maintained. Furthermore, ongoing long-term monitoring programmes for all fauna and flora
types in the Island will be essential to improve the understanding of the conservation
worthiness of the area and to guide future development. LPRC should again work in
collaboration with EPA and local research institutions in gathering this data inclusive of LPRC
technical department.
A low negative impact significance rating was given for the impacts on surface and ground
water quantity as a result of groundwater abstraction during operation. Should groundwater
abstraction be higher than the recharge flux into the aquifer system (Du River and the Atlantic
Ocean), the impact significance rating may be more significant than the current rating. As
such, based on existing information, the degree of confidence in predictions is currently low. It
is therefore recommended that a detailed follow-up intrusive investigation at the proposed site
is undertaken to update the hydrogeological conceptual and numerical models and to confirm
the preliminary calculation results assumed by me.
A summary of the physical and biological environment impacts including premitigation and
residual impact during operation are summarized below in Table 1.2.
Table 1.2 Summary of Residual Physical and Biological Environment Impacts During
Operation
Section Impact Significance(Premitigation) Residual
Impact
Significance
7.2.2 Impacts on
Air Quality
Relating to
Sulphur
Dioxide
(SO2) During
Operation
LOW NEGATIVE LOW
NEGATIVE
7.2.3 Impacts on
Air Quality
Relating to
Nitrogen
Dioxide
(NO2)
During
Operation
MEDIUM
NEGATIVE
LOW
NEGATIVE
7.2.4 Impacts on
Air Quality
Relating to
Particulate
LOW NEGATIVE LOW
NEGATIVE
1.7.4 Summary of Actual and Residual Social Impacts during Construction Phase
A summary of the social impacts including pre-mitigation and residual impact during
construction are summarized below in Table 1.3. Those impacts that have a residual impact
significance of medium negative or higher or a medium positive or higher are discussed.
Increased Pressure on Social Infrastructure and Service Delivery
The development of the RELPRC as part of the broader oil-related activities will prompt an
increase in pressure on the already limited infrastructure and services in the Island through both
Matter
(PM10)
During
Operation
7.3.1 Impact on
Groundwater
and Surface
Water
Quality as a
Result of
Sewage,
Waste and
Effluent
Pollution
MEDIUM
NEGATIVE
LOW
NEGATIVE
7.3.2 Impacts on
Groundwater
Quality as a
Result of
Reinjection
of Produced
Water into
earth
MEDIUM
NEGATIVE
LOW
NEGATIVE
direct
and
indirect
project
activities. This impact, as related to the RELPRC and the broader oil-related activities, has
been given a high negative pre-mitigation rating in terms of the indirect impact of in-migration
into the project area. The direct impact of LPRC employees and contractors on local
7.3.3 Impact on
Surface and
Groundwater
as a Result
of Spillages
and
Leakages
(e.g.
Refueling,
Leaks from
Storage
Tanks, Leaks
from Pipes
etc.)
MEDIUM
NEGATIVE
LOW
NEGATIVE
7.3.4 Impacts on
Surface and
Ground
Water
Quantity as a
Result of
Groundwater
Abstraction
LOW NEGATIVE NEGLIGABLE
NEGATIVE
7.4.1 Loss of
Topsoil
LOW NEGATIVE NEGLIGIBLE
NEGATIVE
7.4.2 Soil
Compaction
LOW NEGATIVE NEGLIGIBLE
NEGATIVE
infrastructure and services was rated as a low negative given that their needs will be met by
LPRC.
Increased Government Revenue
Increased government revenue refers to the payments LPRC will make to the
Liberian Government (e.g. tariffs, rents, and taxes generated from oil companies and
importers), which will translate back into Government spending in the Liberian economy. The
impact of direct payments made to government by LPRC and its importers is not applicable
during the construction phase as no direct payments will be made until operation of the
RELPRC. However, the tax payments as a result of expenditure of goods and services in the
7.5.1 Impact on
Biodiversity
NEGLIGIBLE – LOW
NEGATIVE
NEGLIGIBLE
– LOW
NEGATIVE
Section Impact Significance(Premitigation) Residual
Impact
Significance
7.6.1 Impact on
Local Flora
LOW NEGATIVE LOW
NEGATIVE
7.6.2 Impact on
Local Fauna
MEDIUM
NEGATIVE
LOW
NEGATIVE
7.7.1 Impact on
Terrestrial
and Aquatic
Habitats as a
Result Oil
Spills
LOW NEGATIVE NEGLIGIBLE
NEGATIVE
country will be substantial due to the high capital expenditure during construction. As such,
this impact received a low-medium positive pre-mitigation rating. Based on mitigation, this
impact received a medium positive residual impact.
Improved Access to the LPRC’s Lab for Scientific Research
This impact received a medium positive pre-mitigation rating since the proposed development
in the LPRC may provide an opportunity for scientific studies to be conducted prior to the
commencement of and throughout the construction activities of the RELPRC.
Table 1.3 Summary of Residual Social Impacts during Construction
Section Impact Significance(Premitigation) Residual
Impact
Significance
8.2.1 Employment
– Direct,
Indirect and
Induced
NEGLIGIBLE to
LOW POSITIVE
LOW
POSITIVE
8.2.2 Procurement
of Local
Goods and
Services
NEGLIGIBLE
POSITIVE
NEGLIGIBLE
TO
LOW
POSITIVE
1.8 CONCLUSIONS
1.8.1 Background
The development of the oil industry in Liberia in general and LPRC’s RELPRC specifically, is
taking place in a sensitive and complex socioeconomic and biophysical environment.
Liberia, however, currently faces a large deficit in electricity supply where over 90 percent of
the population are not connected to the national power grid (West Africa Power Pool/mount
coffee). Liberia currently imports all of its petroleum product requirements from abroad as no
products are produced locally. As such the development of the energy sector in Liberia is a
national priority. This has facilitated LPRC’s Memorandum of Understanding (MoU) with the
Government of Liberia especially PPCC to develop oil production associated with RELPRC in
the Island.
However the history of tank disaster throughout the world reveals that problems often arise
undetected due to inaccurate evaluation of both foundation and structural defects. The soil,
water and concrete at the foundation bed are materials of different properties. The level of
interaction cannot be underestimated. Although the interaction is not spontaneous, the solvent
property of water can undermine the configuration of the soils upon which the structure rests.
Monitoring and inspection of crude oil reservoir will ensure continuous safety of the structure
so as to avoid the danger arising from environmental degradation as a resulting from structural
failure.
Monitoring of the tanks should be carried out more frequently for early detection of symptoms
and deficiencies and remedial measures taken as quickly as possible
1.8.2 RELPRC Location
Siting the RELPRC in the Bushrod Island is based on a number of environmental, technical and
financial criteria. The LPRC Jetty has to be located in the NPA in order to access the Tanks
Farm. The flow lines from the Jetty to the RELPRC need to be as short as possible principally
due to the quality of the oil that causes concerns about flow assurance/wax formation and will
need additional pressure pumps to accelerate flows of products. The location of the RELPRC
needs to be as far as possible from the Du River which is pretty much fair based on water
analyses, in an area that will have a limited impact on the terrestrial and wetland habitats and in
close proximity to the escarpment road.
1.8.3 Impacts
The direct biophysical and social impacts of the proposed Project, as assessed in this report, can
be mitigated through stringent implementation of the mitigation measures contained in Sections
7 and 8 of the main report. However, should the facility be expanded or other industries be
attracted to the facility as already done by SRIMEX and ECOFUEL, and CONEX the intensity
and duration of potential cumulative impacts (e.g. on air quality, human health, social services
and conservation) within the Island as a result of actual and perceived impacts could be of
concern. Cumulative and indirect impacts are often more difficult for a particular private oil
company to mitigate. Generally they require significant Government intervention through
strategic planning, in partnership with the oil companies, especially importers and allocation of
the necessary resources to strengthen the local economy and institutional capacity of the area.
As such, it is imperative that LPRC not only strictly adhere to the mitigation measures (actions)
and effectively implement the monitoring measures documented in the Environmental
Management Plan of EPA, but that they also support local government institutions in ensuring
that capacity exists to address indirect and cumulative impacts that may result. Without this
level of commitment from LPRC, the residual and potential cumulative impacts may be more
significant than currently assessed. It is recommended that LPRC continue research dialogue
with EPA and other key stakeholders in order to effectively deal with potential immediate and
long term ‘conflicts’ with environmental and human right activates
1.8.4 Strategic Environmental Assessment
The activities proposed by LPRC for the RELPRC are no different to many other oil operation
activities undertaken throughout the world, however the sensitivity of the surrounding waters
environment within which the RELPRC and oil production and processing as well as
distribution and storage activities will take place are of significance. The RELPRC is also the
first upgrading oil storage of its kind in Liberia
The importance of the oil industry to the development of the Liberia economy should not be
underestimated, however it must be recognized that the development of the oil sector will pose
a threat to the environmental issues if allowed to develop unabated and outside of any strategic
visions.
The compatibility of oil production with conservation, and a subsistence economy which is
largely based on self-employment must be investigated at a higher level to ensure that potential
indirect and cumulative impacts are identified and managed on a regional basis.
While oil activities often have substantial national economic benefits, they seldom offer
significant local benefits in the interests of sustainable development and taking into account
that further oil activities in the Bushrod Island, off-shore into the Atlantic Ocean, and in other
areas within the territory of Liberia are likely, it is recommended that the Government of
Liberia, in partnership with the oil companies, undertake a Strategic Environmental
Assessment (SEA). The SEA should assess the costs and benefits of encouraging the
continuation of a subsistence economy, conservation, tourism, and the development of the oil
sector in Liberia.
The SEA should consider focusing on the following question: “Under what conditions should
the oil sector operate in order to support the sustainable development of the area?” The
conditions referred to in this question may include restrictions or trade-offs to ensure that the
oil sector does not significantly compromise conservation or development.
It should also include an assessment of the willingness to accept a certain amount of risk
associated with the oil industry (i.e. risk of oil spills) and the subsequent potential catastrophic
impacts. The results of the SEA should be used for decision making regarding the future
production of oil and other associated industry in sensitive areas and areas of conservation.
1.8.5 Recommendations
In summary, the implementation of the detailed Environmental Management Plans and
adherence to international best practice, which includes further detailed baseline data collection
and monitoring requirements, will provide a sound basis for mitigating and managing the
majority of direct impacts of the proposed RELPRC. The remaining uncertainties and
‘conflicts’ associated with the potential medium to long-term indirect and cumulative impacts
that may result from further oil distribution and handling throughout the Republic of Liberia
are issues that the Government of Liberia and the oil industry will need to resolve through an
SEA. This assessment should provide a framework within which future conservation,
harvesting of natural resources and oil production can be sustainably developed to benefit both
the local communities and Liberians at large as a whole. It is recommended that LPRC
continue dialogue with EPA and other key stakeholders in order to effectively deal with
potential ‘conflicts’. It is also feasible to consider using API 510 as the current economy is of
great concern to employees and all Liberians at the moment
1.9 REFERNCES
1. Facility piping system for industrial, commercial and health care system; Michael frankel
2. Tanks protection
3. Harrington, J.M., Gill, F.S.., Aw, T.C., Gardiner, K. (1998) Occupational Health.
(149)Ministry of Health and Social Welfare. National Mental Health Policy,2009
4. Ministry of Health and Social Welfare. Annual Report, 2009
5. Ministry of Health and Social Welfare. National strategy and Policy for Community
health services,
2008
6. Ministry of Health and Social Welfare. Capacity Building for the Division of
Environmental and Occupational Health, 2008
7. Ministry of Health Policy and Plan (2007-2011), 2007
8. National Integrated Water Resources Management Policy, 2009
9. Shell Petroleum Development Company of Nigeria (2000): http://www.nigerianoil-
gas.com/industry profile
10. Shell Petroleum Development Company (2003): Oil Industry profile, Nigeria.
http://www.nigerianoil-gas.com/industryprofile
11. World Health Organization WHO Report (2003) Environmental Hazards and the Oil
Industry About we visit:
12. www.geosystems2004.com

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storage tanks

  • 1. Rehabilitation of the Liberia Refinery Company EIA Proposed recommendation Environmental Impact Assessment for the Proposed/approved rehabilitation of the LPRC. July 2015
  • 2. RECOMMENDED REPORT Prepared by: ANSUMANA E.M. DUKULY, JR.
  • 3. 1.1 INTRODUCTION The primary petroleum product storage tanks area in Liberia is the Liberia Petroleum Refinery Company. This area is located in the southcenterrnmost part of the west of Monrovia, specifically Bushrod Island. The Liberia Refinery Company stretches from NPA of Liberia and as far as to Clara town, in the West. Although varying in width, it is approximately 3.2 km wide, extending in some areas into the National Port Authority (NPA). The Government of Liberia (GoL) has divided the Freeport of Monrovia (NPA) into three PST areas. Liberia Petroleum Refinery Company is located towards the west extremity of the NPA and is covered by LPRC and SRIMEX & ECOFUEL joint venture. LPRC holds interests in developing and expanding the PST.
  • 4. 1.2 APPROACH AND METHODOLOGY The purpose of the EIA is to provide relevant, understandable and objective information to inform decisions regarding the authorization and expansion of the Rehabilitation of the Liberia Refinery Company EIA (RELPRC) in Monrovia, Liberia. This EIA consists of the following four phases: Screening; Scoping; Specialist Studies; and Integration and Assessment. Screening Based on limited capacities the initial screening phase identified that a full EIA was required as petroleum facilities engineering and production have classified as a Category III activity in terms of the Environmental Impact Assessment Regulations (1998) promulgated under the National Environment Act of 2003 which was amended in 2010 of Liberia. Scoping The second phase of the EIA process was Scoping. The objectives of Scoping were the following: 1. to identify issues of serious environmental concern; 2. ensure all potential impacts, key issues and reasonable alternatives are identified; and 3. Ensure informed, transparent and accountable decision-making by the Environment Protection Agency/Authority (EPA). As part of the scoping phase, a consultation process was conducted manually with an opportunity to raise concerns and comment on the potential impacts and merits of RELPRC development. Input was captured in order to focus the assessment on key concerns, and to
  • 5. better understand expectations of those potentially affected. Figure 1.2 identifies the key identified during consultation.
  • 6. Figure 1.2 Key Stakeholder Groups Project participants (Liberia Petroleum and Refinery Company management and employees) Local community members Vulnerable groups (e.g. general residents) Local businesses around the LPRC’s Facility National and level authority especially EPA with references from their achieves Locals and Local environment and social NGOs Media groups A range of issues were raised during consultation. The main issues include the following: Present Site location and its environmental effects – Some business people and locals around LPRC mentioned that site alternatives needed to clearly outline both the positive and negative impacts of the RELPRC. Numerous locals including LPRC’s employees indicated their preference for the RELPRC to be located outside Bushrod Island because of serious environmental issues raised as will be explained later. Awareness Raising and Community Liaison - Many locals and national agencies feel that LPRC should play a more active role in raising awareness about the project specifically and oil storage tanks in general and especially for example the Ganta Storage Tank Terminal. Locals and residents here had been confused because of a number of misperceptions amongst them that could easily have been clarified if LPRC has had the time to adequately inform locals especially in nimba and had a proactive community liaison strategy. As the stakeholders in nimba have requested that LPRC improve their community liaison capabilities not withstanding this has some political configuration and lobbying effects.
  • 7. Fish and Fishing – The majority of fishermen around Du River, especially West Point raised concerns about the impact on the numbers of fish during and since the operation phase of LPR C commenced. The impact of the current ban on night fishing was also raised as a concern since it was felt that it may have severe consequences on the local fishing economy and affect peoples’ income and livelihoods . Waste Management -A number of serious observations were made in LPRC’s Tanks Farm and the kind of waste that the RELPRC is going to generate and how that waste was going to be handled or disposed is of major environmental concern. LPRC, beyond all environmental reasons is one of the most polluters of the city as far as environmental analyses are concern. Oil Spills and leakages – resident will want to know if LPRC had any management measures in place that would address clean-ups of oil spills. The impact of oil spills on fish stocks and water resources was also a significant concern to local stakeholders. Air Quality – locals and employees are extremely concerned about the impact of the RELPRC and the aftermath especially operational periods on air quality, during flaring/flushing/dewatering of tanks. Employees and locals also wanted to know what measures RELPRC would put in place to mitigate air pollution and greenhouse gases. Flushing and dewatering - Given the sensitivity of the environment in the project area and the dry conditions during half of the year, locals were concerned about the risks of fire and potentially other risks associated with Flushing and dewatering that could threaten the environment. Community benefits – An overwhelming number of residents expressed the view that the project should ensure that the local people experience social transformation and that they must directly benefit from the project. For example many of the locals were anticipating electricity provision to the whole of Bushrod Island since the hydropower is not operational.
  • 8. Other issues raised included issues surrounding: project life span, the need for a Strategic Environmental Assessment, community benefits, security and conflict, and perceptions of corruption (everyone’s concern). Other issues raised included issues surrounding: project life span, the need for a Strategic Environmental Assessment, community benefits, security and conflict, and perceptions of corruption (everyone’s concern). Specialist Studies Specialist studies included baseline information gathering relating to the affected environment and an assessment of the impacts associated with the proposed development. In support of the EIA, the following specialist studies were undertaken: Visual; Air quality; Waste management; Ground and surface water; Flora and fauna; and Socio-economic Integration and Assessment A synthesis of the baseline information and impact assessment undertaken, which addresses the key issues identified during the scoping process, is integrated into the Environmental Impact Statement. Potential impacts are assessed according to predefined assessment criteria and mitigation measures developed for the impacts.
  • 9. 1.3 LEGAL AND POLICY FRAMEWORK Liberia has a wide array of legislation that promotes the protection of the environment. A number of Policies, Acts and Regulations were taken into account during the EIA process though the EPA, implementer arm of the processes is weak. An Environmental Impact Study (EIS) has been compiled as part of the EIA process in accordance with the regulatory requirements stipulated in the EIA Regulations, 2003 promulgated under the National Environment Act of 2010. 1.4 PROJECT DESCRIPTION Rehabilitation and Expansion of Liberia Petroleum Refinery Company; Product Storage Terminal (RELPRC/PST) will consist of the following: Supply Pipelines from the Jetty to the tank farm three new pipelines (8, 10 and 12 inch diameter) are to be installed along the onshore Jetty walkway to the product terminal replacing existing pipelines. LPRC Product Storage Terminal is comprising two adjoining tank fields namely: Mobile and Texaco with a total Storage capacity of 480 thousand barrels including 15 existing storage tanks: a) Storage Tanks The new storage tanks construction shall include shells, floors, roofs, foundations, access stairways, railings and handrails, together with venting and gauging mechanisms. b) Piping Network The new piping network shall include valves, flanges, fittings and pipe support, designed to provide full transfer flexibility from the pump station to each product storage tank and to the loading station.
  • 10. Loading Rack and Pumping a) Tank truck loading To undertake the complete redesign and build a new loading and pumping facilities with increased loading capacity. To install top loading with provision for bottom loading. To include essential components, including meters, loading arm, separators and filters. To install a new concrete pad for the loading rack, accompany trenches to recover accidental spills. b) Loading Arm Pumping Station To install all loading and transfer pumps on one concrete pad large enough for future pumping capacity, including additional pumps to meet projected demand. Environmental Protection a) Prevention actions To provide environmental protection facilities and procedures to include the prevention and full recovery of accidental spills and contaminated surface waters originating from the storage tank slab, pump stations and truck loading areas, which have to be directed to an adequately- sized API oil separator. To install floating pads on gasoline tanks to reduce air pollution, but also to reduce gasoline tank breathing losses. b) Remediation To conduct an environmental audit to establish the nature and the extent of soil and /or water contamination and identify the extent of remediation required. Fire Protection a) A totally new Fire Water distribution network has to be devised and installed b) Install all new foam making equipment (chambers) Power Generation The contractor shall carried out a thorough and full assessment of the existing electric system and will provide a report in the context of immediate modifications which may be required for adaption with the PST project and to install new power generation system to meet demand.
  • 11. Security To install adequate security lighting, strategically located inside and around the Tank field perimeter of meters and along the shore supply pipelines Safety To verify and correct non conformities in the actual layout of Tanks within the terminal, taking into consideration specified regulatory safe distances between tanks as per their respective dimensions, distances loading racks and property limits, public roads, fire protection equipment, laboratory, railroads, together with adjacent lodgings and office buildings, all according to applicable local or international regulations CRITIQUE OF THE PROJECT FLOW A) Storage Tanks If we looked at the general integrity of all the tanks owned by LPRC, it seems pretty well stable to cut down costs attached. However, there is going to be some technical demands well certain from the engineering team of LPRC. INTEGRITY of tanks one (1), three (3), five (5), six (6), seven (7), eight (8), four hundred and three (403), four hundred and four (404), four hundred and seven (407), and finally four hundred and eight (408) worth a lot to explain. As a result of serious environmental hazards resulting from reservoir failures there is need to carryout Periodic monitoring of the reservoir. Above surface vertical cylindrical reservoir used in Oil and gas industries are constructed of steel and over the years many of the structures have corroded and leaked petroleum products into the soils thus contaminating ground water and the environment. Leaking reservoir can be a source of groundwater problem as the petroleum which they carry contains toxic compounds including benzene, toluene, xylene and ethylene dibromide. These compounds are thought to cause cancer, and pose a number of health risks including nervous system damage, reproductive problem and immune system depression. The soils and geological condition at the structure locations can also affect ground water contamination.
  • 12. OIL STORAGE TANKS AT THE LPRC TERMINAL Reservoirs/tanks at the LPRC terminal were constructed between 1956 and 1970s. There are at the Moment 15 oil storage reservoir, the shortest in height is around approximately 13m in height and diameter 36.5m while longest is 17.1m in height 31m in diameter. The structural integrity of these reservoirs/tanks has been of major concern to both local community and Environmentalists. Although API Standards have not remained the industry standard relative to reservoir inspection and maintenance, the frequency of testing and inspection can also be affected by various state and local regulations. The schedule of this inspection process depend on a number of factors which include: the age, their Proximity to groundwater, the leak records, the date of the last integrity test, the construction material used, the product stored, soil condition etc. Reservoir at LPRC farm is half way bounded with a bound walls which measuring 250m by 150m and at a height of 12m. The bound walls are to accommodate and contain any spill that may result from failure of any of the reservoir. STRUCTURAL HEALTH MONITORING Reservoir/tanks used by oil LPRC are cylindrical in shape. As a result of age, non-uniform settlement of the foundation, geological conditions loading and offloading, war, abandonment, negligent, non- technical team over the years, oil temperature, primary and secondary settlement of sediments results in radial deformation or out of roundness of the reservoir. This results in the binding of the floating roof or in cone-roof tanks displacement. Out of roundness may result in the upper shell course buckling. Shell out of roundness may result in gaps between reservoir shell and their hydrocarbon emission into the environment occurred. As a safety measure, each reservoir needs to be monitored periodically TANK 1 This tank has a capacity of approximately 3400000 US Gallons, not neglecting other causes attached, and based on the observation of the tank, it seems likely that this tank can be revamped using API 510 standards and it will maintain its stability status as before, hence bringing cost reduction (CAPEX), this will be explained in subsequent paper presentations.
  • 13. It is advisable to use API 510 by removing the base-floor and adjusting the already tilted ankles and circumference and or reassessing the tank before management final decisions are taken. TANK 3 This tank has a capacity of approximately 2600000 US Gallons, the tanks has been quantified if not replaced, however, based on best practices it seems not completed as sprinklers/terminal cooling system are not yet up to date, but almost. TANK 4 This tank has a capacity of approximately 2500000 US Gallons. The floating roof system is good and based on standards many business people will want to go for it but when it comes to integrity and stability, the cone roof or fixed roof is always better than it. Others might want to argue about product losses etc. but no matter what however, no tank is “product lose free” therefore ten it is 100% advisable to build fixed cone roof. TANK 5 This tank has a capacity of approximately 1300000 US Gallons. Looking at the tank’s conditions, we first assume that it is old or outdated, but this doesn’t mean that API 510 cannot be applied or implemented. Please cut down cost and improve stability. The department of petroleum at LPRC will give you much needed briefings. TANKS 6, 7, 8,403,404,407,408 This tank has a capacity of approximately 1300000, 700000, 430000, 660000, 418000, 410000 US Gallons respectively. Similarly all other API applications and standards should be applied to avoid unnecessary wasteful costs not neglecting API 510.
  • 14. PIPING SYSTEM Installing an outer pipe around an inner pipe has been found to prevent the release of hazardous liquids being transported in the inner pipe. This system as a whole is called a secondary contained piping system, or double-walled pipe. A major use for these systems is for transporting liquid fuel, “Liquid Fuel Storage and Dispensing Systems.” There are no generally recognized codes for dimensions. The interior pipe transporting the liquid is called the carrier or primary pipe. The outer pipe around the carrier pipe is called the containment pipe or secondary containment. A detail of a typical double- contained pipe is schematically an illustration to be done by LPRC’s Petroleum Engineers. The two pipes are to be kept apart by spacers, these are often called frogs or spiders by manufacturers. Double-wall systems are manufactured from many different piping materials. There is no requirement for the primary and secondary pipe to be made of the same material, except where a possible incompatibility may exist. the LPRC piping system is been one of the most vulnerable ever, therefore, then it is highly recommended to consider all pipes being buried underground to control fire security, spillages as well as environmental sensibility . REMEDIATION AND SECURITY Watering and water system will not be meant only for tanks, if we looked at the roofs of the pump house, and the loading rack, you will understand that there is a need if not a serious one to cane the roof as from zinc to clay, the distance of the loading rack should be at least 120 ft. away from offices, a firefighting sprinkler should be installed within the roof of the loading racks as well as all offices within the LPRC vicinity because wit fire nothing is ever safe, therefore safety first. The contingency pipeline line, if it is meant for the future then should be halted and brought within the NPA fence instead of its present location, because 15 to 25years from now the tiding will be different. 1.5 SITE SELECTION As part of the EIA process, a site selection study was undertaken from June – July 2015 in order to identify the most appropriate area for the RELPRC/PST. Hence the old site is considered as fairly suitable but not advisable for the future because of cluster impedance and
  • 15. population of the environment as For oil escarpment, that could result in an unacceptable environmental impact, RELPRC/PST would also result in an additional US$ 30 million capex (capital expenditures) and US$ 3.3 million opex (operational expenditures) affecting the financial viability of the Project summing up to $33.3 million tis estimate is an approximation based on qualitative analyses (quick look). Tis estimate can be reduced to $12 million to $15 million if considerations are given to API 510 Based on such a result, LPRC’s preference will be considered for the following reasons: Reduced capital expenditure (capex) and operational expenditure (opex) – this is seen as a serious consideration affecting decision making with the members of the board, as the additional costs associated would make the financial viability of the RELPRC/PST unfeasible; Greater energy efficiency and hence lower fuel consumption; Lower technical risk – e.g. no flow assurance or seismic damage risks associated with a pipeline up the escarpment because the seismic zone in which Liberia falls is approximately 1 at the magnitude level; and Lower security risk - security can be better controlled with numerous locations close to the RELPRC/PST site, as such, Site formed the focus of the RELPRC/PST EIA. 1.6 Social The population of the Bushrod Island is settled at 6 relatively small landing sites and 1 fishing location at West Point along the shore. The overall population of the Island is relatively high although it has increased with time as a result of the improved peace initiatives of the United Nations and ECOWAS, the attraction of fishing and people coming to the West Point even from neighboring in search of self-employment from Senegal and Ghana. There has been considerable population growth over the past few years, with rapid growth expected to continue. Education levels are still very low in the republic, with respondents commenting that the value of education is not fully understood. The population living in the island are predominantly semi-illiterate, with literacy rates estimated to be approximately 40 percent and as low as 15 percent amongst the women. Poor education levels have also been attributed to parents taking
  • 16. their children out of school and in facts as a result of accelerated Ebola virus in the sub region of Mano River, to assist with fishing and other household responsibilities. With these problems prevailing every day, LPRC will need to provide more scholarships for students at all level both international and national. It was reported that the common diseases within the island include malaria (including cerebral malaria), dysentery, diarrhea, cholera, sexually transmitted diseases (STDs), meningitis, maternal mortality and anemia in children. Headaches and coughs were also reported to be a persistent problem most of which are associated with pollution in other ways. 1.7 SUMMARY OF ACTUAL AND RESIDUAL IMPACTS 1.7.1 Nature of Impacts A key element of ongoing environmental and socio-economic management is to address uncertainty, through collecting information, additional assessment and, where necessary, the development of further mitigation and management measures. As the project moves forward and on-the-ground implementation confirms or puts in to question the nature or extent of impacts discussed below, these will need to be addressed as part of the ongoing updating and refining of the Environmental Management Plan (EMP). It is vital to stress that the residual impact significance ratings provided in this EIA are based on LPRC’s bending adherence to the mitigation measures (actions) and ineffective implementation of the monitoring measures. Without this level of commitment from LPRC, the residual impacts will be more significant than currently assessed.
  • 17. 1.7.2 Summary of Actual and Residual Physical and Biological Environment Impacts during Construction Phase During the construction phase, only the impact on local fauna necessitates a medium negative residual impact. Although the remaining physical impacts received a residual impact of either low negative or negligible negative, the biggest impact will be on waste, spills, fauna and flora. During the construction phase of the Project, the activities to be carried out will involve site clearance for the separator of produced water and temporary and permanent accommodation facilities, excavation of flow lines trenches, construction of roads in RELPRC/PST area etc. This will entail flora clearance and thus disturbance of the local flora and fauna and potential habitat degradation, destruction or fragmentation thus affecting biodiversity. The main habitat to be impacted will be the snakes with a loss of approximately 0.08 percent of the entire facility. A summary of the physical and biological environment impacts including pre-mitigation and residual impact during construction are summarized below in Table 1.1. Table 1.1 Summary of Actual and Residual Physical and Biological Environment Impacts During Construction 1.7.3 Summary of Actual and Residual Physical and Biological Environment Impacts during Operation Phase Although no impacts will be received as a residual impact rating of medium negative or higher during the operation phase, some discussion on the impacts to air quality and flora is pertinent. While the air quality dispersion modelling undertaken during the baseline studies provided a worst case scenario and some uncertainties exist as a result of the lack of measured meteorological data, exceedances in the NO2 1-hour WHO ambient air quality guideline in the
  • 18. Bushrod Island are predicted. While these exceedances are unlikely to have any health impact on local communities as a result of the RELPRC, should the facility be expanded or should other polluting industries be attracted to the area, the cumulative impact could be of concern. As such, it is imperative that detailed monitoring of ambient air quality be continued while monitoring of meteorological data also continued so as to generate a long term data set, LPRC petroleum Engineers will take care of that. It is therefore assumed that a combination of technology options, engineering design and siting have achieved the desired effect in the ambient environment, i.e. a reduction in the predicted exceedances of the WHO 1-hour guideline for NO2 during normal operating conditions. The operational phase will not have the same severity of impact as the construction phase for fauna and flora, as over time, most animals (snakes and insects as well as fish) will adjust to the increased disruption within the life cycle of animals and human habitats on the Island which are critical habitats, hence decreasing the level of protection from further disturbance. It is therefore essential that LPRC work in close cooperation with EPA and the existing concessionaire in terms of ensuring that the conservation worthiness of these habitats is maintained. Furthermore, ongoing long-term monitoring programmes for all fauna and flora types in the Island will be essential to improve the understanding of the conservation worthiness of the area and to guide future development. LPRC should again work in collaboration with EPA and local research institutions in gathering this data inclusive of LPRC technical department. A low negative impact significance rating was given for the impacts on surface and ground water quantity as a result of groundwater abstraction during operation. Should groundwater abstraction be higher than the recharge flux into the aquifer system (Du River and the Atlantic Ocean), the impact significance rating may be more significant than the current rating. As such, based on existing information, the degree of confidence in predictions is currently low. It is therefore recommended that a detailed follow-up intrusive investigation at the proposed site
  • 19. is undertaken to update the hydrogeological conceptual and numerical models and to confirm the preliminary calculation results assumed by me. A summary of the physical and biological environment impacts including premitigation and residual impact during operation are summarized below in Table 1.2. Table 1.2 Summary of Residual Physical and Biological Environment Impacts During Operation Section Impact Significance(Premitigation) Residual Impact Significance 7.2.2 Impacts on Air Quality Relating to Sulphur Dioxide (SO2) During Operation LOW NEGATIVE LOW NEGATIVE 7.2.3 Impacts on Air Quality Relating to Nitrogen Dioxide (NO2) During Operation MEDIUM NEGATIVE LOW NEGATIVE 7.2.4 Impacts on Air Quality Relating to Particulate LOW NEGATIVE LOW NEGATIVE
  • 20. 1.7.4 Summary of Actual and Residual Social Impacts during Construction Phase A summary of the social impacts including pre-mitigation and residual impact during construction are summarized below in Table 1.3. Those impacts that have a residual impact significance of medium negative or higher or a medium positive or higher are discussed. Increased Pressure on Social Infrastructure and Service Delivery The development of the RELPRC as part of the broader oil-related activities will prompt an increase in pressure on the already limited infrastructure and services in the Island through both Matter (PM10) During Operation 7.3.1 Impact on Groundwater and Surface Water Quality as a Result of Sewage, Waste and Effluent Pollution MEDIUM NEGATIVE LOW NEGATIVE 7.3.2 Impacts on Groundwater Quality as a Result of Reinjection of Produced Water into earth MEDIUM NEGATIVE LOW NEGATIVE
  • 21. direct and indirect project activities. This impact, as related to the RELPRC and the broader oil-related activities, has been given a high negative pre-mitigation rating in terms of the indirect impact of in-migration into the project area. The direct impact of LPRC employees and contractors on local 7.3.3 Impact on Surface and Groundwater as a Result of Spillages and Leakages (e.g. Refueling, Leaks from Storage Tanks, Leaks from Pipes etc.) MEDIUM NEGATIVE LOW NEGATIVE 7.3.4 Impacts on Surface and Ground Water Quantity as a Result of Groundwater Abstraction LOW NEGATIVE NEGLIGABLE NEGATIVE 7.4.1 Loss of Topsoil LOW NEGATIVE NEGLIGIBLE NEGATIVE 7.4.2 Soil Compaction LOW NEGATIVE NEGLIGIBLE NEGATIVE
  • 22. infrastructure and services was rated as a low negative given that their needs will be met by LPRC. Increased Government Revenue Increased government revenue refers to the payments LPRC will make to the Liberian Government (e.g. tariffs, rents, and taxes generated from oil companies and importers), which will translate back into Government spending in the Liberian economy. The impact of direct payments made to government by LPRC and its importers is not applicable during the construction phase as no direct payments will be made until operation of the RELPRC. However, the tax payments as a result of expenditure of goods and services in the 7.5.1 Impact on Biodiversity NEGLIGIBLE – LOW NEGATIVE NEGLIGIBLE – LOW NEGATIVE Section Impact Significance(Premitigation) Residual Impact Significance 7.6.1 Impact on Local Flora LOW NEGATIVE LOW NEGATIVE 7.6.2 Impact on Local Fauna MEDIUM NEGATIVE LOW NEGATIVE 7.7.1 Impact on Terrestrial and Aquatic Habitats as a Result Oil Spills LOW NEGATIVE NEGLIGIBLE NEGATIVE
  • 23. country will be substantial due to the high capital expenditure during construction. As such, this impact received a low-medium positive pre-mitigation rating. Based on mitigation, this impact received a medium positive residual impact. Improved Access to the LPRC’s Lab for Scientific Research This impact received a medium positive pre-mitigation rating since the proposed development in the LPRC may provide an opportunity for scientific studies to be conducted prior to the commencement of and throughout the construction activities of the RELPRC. Table 1.3 Summary of Residual Social Impacts during Construction Section Impact Significance(Premitigation) Residual Impact Significance 8.2.1 Employment – Direct, Indirect and Induced NEGLIGIBLE to LOW POSITIVE LOW POSITIVE 8.2.2 Procurement of Local Goods and Services NEGLIGIBLE POSITIVE NEGLIGIBLE TO LOW POSITIVE
  • 24. 1.8 CONCLUSIONS 1.8.1 Background The development of the oil industry in Liberia in general and LPRC’s RELPRC specifically, is taking place in a sensitive and complex socioeconomic and biophysical environment. Liberia, however, currently faces a large deficit in electricity supply where over 90 percent of the population are not connected to the national power grid (West Africa Power Pool/mount coffee). Liberia currently imports all of its petroleum product requirements from abroad as no products are produced locally. As such the development of the energy sector in Liberia is a national priority. This has facilitated LPRC’s Memorandum of Understanding (MoU) with the Government of Liberia especially PPCC to develop oil production associated with RELPRC in the Island. However the history of tank disaster throughout the world reveals that problems often arise undetected due to inaccurate evaluation of both foundation and structural defects. The soil, water and concrete at the foundation bed are materials of different properties. The level of interaction cannot be underestimated. Although the interaction is not spontaneous, the solvent property of water can undermine the configuration of the soils upon which the structure rests. Monitoring and inspection of crude oil reservoir will ensure continuous safety of the structure so as to avoid the danger arising from environmental degradation as a resulting from structural failure. Monitoring of the tanks should be carried out more frequently for early detection of symptoms and deficiencies and remedial measures taken as quickly as possible 1.8.2 RELPRC Location Siting the RELPRC in the Bushrod Island is based on a number of environmental, technical and financial criteria. The LPRC Jetty has to be located in the NPA in order to access the Tanks Farm. The flow lines from the Jetty to the RELPRC need to be as short as possible principally due to the quality of the oil that causes concerns about flow assurance/wax formation and will need additional pressure pumps to accelerate flows of products. The location of the RELPRC
  • 25. needs to be as far as possible from the Du River which is pretty much fair based on water analyses, in an area that will have a limited impact on the terrestrial and wetland habitats and in close proximity to the escarpment road. 1.8.3 Impacts The direct biophysical and social impacts of the proposed Project, as assessed in this report, can be mitigated through stringent implementation of the mitigation measures contained in Sections 7 and 8 of the main report. However, should the facility be expanded or other industries be attracted to the facility as already done by SRIMEX and ECOFUEL, and CONEX the intensity and duration of potential cumulative impacts (e.g. on air quality, human health, social services and conservation) within the Island as a result of actual and perceived impacts could be of concern. Cumulative and indirect impacts are often more difficult for a particular private oil company to mitigate. Generally they require significant Government intervention through strategic planning, in partnership with the oil companies, especially importers and allocation of the necessary resources to strengthen the local economy and institutional capacity of the area. As such, it is imperative that LPRC not only strictly adhere to the mitigation measures (actions) and effectively implement the monitoring measures documented in the Environmental Management Plan of EPA, but that they also support local government institutions in ensuring that capacity exists to address indirect and cumulative impacts that may result. Without this level of commitment from LPRC, the residual and potential cumulative impacts may be more significant than currently assessed. It is recommended that LPRC continue research dialogue with EPA and other key stakeholders in order to effectively deal with potential immediate and long term ‘conflicts’ with environmental and human right activates 1.8.4 Strategic Environmental Assessment The activities proposed by LPRC for the RELPRC are no different to many other oil operation activities undertaken throughout the world, however the sensitivity of the surrounding waters environment within which the RELPRC and oil production and processing as well as
  • 26. distribution and storage activities will take place are of significance. The RELPRC is also the first upgrading oil storage of its kind in Liberia The importance of the oil industry to the development of the Liberia economy should not be underestimated, however it must be recognized that the development of the oil sector will pose a threat to the environmental issues if allowed to develop unabated and outside of any strategic visions. The compatibility of oil production with conservation, and a subsistence economy which is largely based on self-employment must be investigated at a higher level to ensure that potential indirect and cumulative impacts are identified and managed on a regional basis. While oil activities often have substantial national economic benefits, they seldom offer significant local benefits in the interests of sustainable development and taking into account that further oil activities in the Bushrod Island, off-shore into the Atlantic Ocean, and in other areas within the territory of Liberia are likely, it is recommended that the Government of Liberia, in partnership with the oil companies, undertake a Strategic Environmental Assessment (SEA). The SEA should assess the costs and benefits of encouraging the continuation of a subsistence economy, conservation, tourism, and the development of the oil sector in Liberia. The SEA should consider focusing on the following question: “Under what conditions should the oil sector operate in order to support the sustainable development of the area?” The conditions referred to in this question may include restrictions or trade-offs to ensure that the oil sector does not significantly compromise conservation or development. It should also include an assessment of the willingness to accept a certain amount of risk associated with the oil industry (i.e. risk of oil spills) and the subsequent potential catastrophic impacts. The results of the SEA should be used for decision making regarding the future production of oil and other associated industry in sensitive areas and areas of conservation.
  • 27. 1.8.5 Recommendations In summary, the implementation of the detailed Environmental Management Plans and adherence to international best practice, which includes further detailed baseline data collection and monitoring requirements, will provide a sound basis for mitigating and managing the majority of direct impacts of the proposed RELPRC. The remaining uncertainties and ‘conflicts’ associated with the potential medium to long-term indirect and cumulative impacts that may result from further oil distribution and handling throughout the Republic of Liberia are issues that the Government of Liberia and the oil industry will need to resolve through an SEA. This assessment should provide a framework within which future conservation, harvesting of natural resources and oil production can be sustainably developed to benefit both the local communities and Liberians at large as a whole. It is recommended that LPRC continue dialogue with EPA and other key stakeholders in order to effectively deal with potential ‘conflicts’. It is also feasible to consider using API 510 as the current economy is of great concern to employees and all Liberians at the moment 1.9 REFERNCES 1. Facility piping system for industrial, commercial and health care system; Michael frankel 2. Tanks protection 3. Harrington, J.M., Gill, F.S.., Aw, T.C., Gardiner, K. (1998) Occupational Health. (149)Ministry of Health and Social Welfare. National Mental Health Policy,2009 4. Ministry of Health and Social Welfare. Annual Report, 2009 5. Ministry of Health and Social Welfare. National strategy and Policy for Community health services, 2008 6. Ministry of Health and Social Welfare. Capacity Building for the Division of Environmental and Occupational Health, 2008 7. Ministry of Health Policy and Plan (2007-2011), 2007
  • 28. 8. National Integrated Water Resources Management Policy, 2009 9. Shell Petroleum Development Company of Nigeria (2000): http://www.nigerianoil- gas.com/industry profile 10. Shell Petroleum Development Company (2003): Oil Industry profile, Nigeria. http://www.nigerianoil-gas.com/industryprofile 11. World Health Organization WHO Report (2003) Environmental Hazards and the Oil Industry About we visit: 12. www.geosystems2004.com