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ENVIRONMENTAL AUDIT REPORT Of
LARABEE ENTERPRISES LIMITED Plot 62, Phase 3, Sharada Industrial Estate, Kano BY PREPRA NIGERIA 31/32BELLO ROAD, KANO Email:
[email protected]
OCTOBER, 2014
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AUDIT PREPARERS ALIYU BABA NABEGU, PhD, MWMS, mni Lead Consultant, Prepra Nig. Ltd SULAIMAN MUHAMMAD B. Eng Civil Engineer, Prepra Nig. Ltd ALIYU M GAMU Head, Human Resources, Larrabee Ent ltd PHILLIP MONDAY SHUAIBU Head, Engineer, Larrabee Ent. Ltd HARUNA UMAR SANI Laboratory Technologist, Prepra Nig. Ltd BELLAMKONDA SREENIVASARAO Production Manager, Larrabee Ent.ltd AMINU ALIYU Technical Department, Prepra Nig.ltd
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LIST OF FIGURES Figure 1 : Location of Sharada Industrial Estate within Kano metropolis
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LIST OF TABLES Table 1:
Profile of Larrabee enterprises Limited
Table 2:
Comparison of Larrabee effluent analysis with NESREA standards
Table 3:
Soil Analysis within Larrabee factory
Table 4:
Noise level in some sections of Larrabee factory
Table 5:
Air quality in the Larrabee factory
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TABLE OF CONTENT Title Page List of Prepares List of figures List of Tables Table of contents Acknowledgement Exclusive Summery
i ii iii iv v – ix x xi - xii
CHAPTER ONE: 1.0 INTRODUCTION 1.1 Background 1.2 Objectives of the Environment Audit 1.3 Terms of Reference of the EA 1.4 The Audit Criteria 1.5 Scope of the Audit 1.6 Approach and Methods 1.6.1 Pre - Audit phase 1.6.2 On site - Phase 1.6.2.1Conducting Opening Meeting with Factory Manager and Sites Personnel 1.6.2.2 Undertaking review of relevant documents 1.6.2.3 Conducting Staff Interview to obtain Information on Actual Practices 1.6.2.4 Conducting on Site Inspection with relevant Audit Checklist 1.6.2.5 Collecting Sample for Analysis 1.6.2.5.1 Procedure for Collection of Water Samples 1.6.2.5.2 Evaluation of the quality of waste water 1.6.2.5.3 Measurement of Temperature, pH and Conductivity 1.6.2.5.4 Determination of total solids, suspended, Dissolved solids and Total ash 1.6.2.5.5 Conducting Material balance 1.6.2.5.6 Debriefing of the management on audit findings, recommended corrective actions 1.6.2.5.7 Environmental Monitoring data 1.6.3 Post Audit Activities 1.6.3.1 Actions in post Audit phase 1.6.3.2 Evaluation of Findings
1 1-3 3-4 4 5 6 6 6-8 8 8
5
8-9 9 9 10 10 10 10 - 11 11 11 -12 12 -13 13 13 13-14 15
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1.6.3.3 Steps after analyzing the findings 1.6.3.4. Implementation of the Action plan 1.6.4 Audit period
15 15 15
CHAPTER TWO: 2.0 OVERVIEW OF LARRABEE ENTERPRISES LTD 2.1 Company Profile 2.2 Location of Larrablee Factory 2.3 The Process Technology 2.3.1 Raw Material for the Tanning industry 2.3.2 The tanning Process 2.3.2.1 Currying 2.3.2.2 Beam House operations 2.3.2.3 Soaking 2.3.2.4 Liming 2.3.2.5 De-liming and Bating 2.3.2.6 Pickling 2.3.2.7 Retanning
16 16 17 - 18 18 18 -19 19 19 -20 20 20 20 - 21 21 21 - 22 22 -23
CHAPTER THREE: 3.0 BASELINE ENVIRONMENTAL ASSESSMENT 3.1 Description of the Surrounding Environment 3.2. Existing Environmental management system 3.2.1Environmental Policy of Larrabee Enterprises Limited 3.2.2 Implementation of the EMP 3.2.3 Compliance with Environmental laws and regulations in Larrabee
24 24 24 24 - 26 26 - 27 27 - 29
CHAPTER FOUR: 4.0 AUDIT FINDINGS 4.1 Observation and Evaluation of General housekeeping 4.1.1Waste generation from Larrabee 4.1.2 Impact valuation 4.1.2.1. Waste Water Disposal 4.1.1.2 Solid Water disposal 4.1.2.3 Compatibility 4.1.2.4 Fuel Dump 4.1.2.5 Cloakroom/Conveniences 4.1.2.6 Safety signs 4.1.2.7 Soil Analysis 4.1.2.8 Muster point 4.1.2.9 Fire Extinguisher
30 30 30 – 31 31 31- 33 33- 34 34 34 34 35 35 35 36
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4.1.2.10 Illumination 4.1.2.11Noise level 4.1.2. 12 Air Quality 4.1.3 Compliance with extant regulations 4.1.3.1Compliance with Environmental Regulations 4.2.1.2 Compliance to other regulations 4.1.2 Socio- Economic Impact
36 36 36- 37 37 37 - 38 38 38-39
CHAPTER FIVE: 5.0 RECOMENDATIONS 5.1 General Recommendations 5.2 Specific Recommendations 5.2.1 Elimination of Waste 5.2.2 Reuse of waste 5.2.3 Recycling of Waste 5.2.4 Disposal after compaction, drying or other treatment 5.2.5 R Retention /Redirect 5.2.6 Separation/concentration 5.2.7 Determination of specific water consumption 5.2.8 Produce by products from waste generated 5.2.9 Reducing Noise level and Gaseous pollutants 5.2.10 Compliance to all extant regulations 5.2.11 Compliance to all extant regulations
40 40 41 41 41 41 42 42 43 43 43- 44 44 44 44
CHAPTER SIX: 6.0 FOLLOW UP PLAN 6.1 Completion and Submission of EA 6.1.1 Submission of EA report
45 45 45 6.1.2 Monthly effluent monitoring and sending results to NESREA and 45 Kano state Ministry of Environment 6.1.3 Implementation Follow up on the management of the company’s EMP
43
6.1.4 Provision of adequate safety equipment
45
6.1.5 Provision of firefighting equipment in strategic locations of the 45 factory identified 6.1.7 Awareness training for staff
45
6.1.7 Quarterly inspection
45
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6.1.8 Establishment of quality assurance unit to ensure timely repairs to 45 leaking oil/water pipes CHAPTER SEVEN: 7.0 CONCLUSION
46
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October 1, 2014 ACKNOWLEDGEMENT
Prepra Nigeria acknowledges the full cooperation and support of the management and staff of Larrabee Enterprises limited. In particular, the support and disposition of the chairman/CEO Mustapha Shour has been invaluable to the success of this report. We also recognize and immensely appreciate the assistance from the heads of Engineering and Human resources as well as the production Manager. Prepra Nig. Ltd is also grateful to Larrabee Enterprises limited for its patronage and the opportunity to be involved in the company’s quest towards the environmental sustainability. Prepra Nigeria ltd wishes to stress that in line with its policy, all information obtained in the course of this Audi exercise as well as those contained in this report will be accorded the strictest confidentiality.
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October 1, 2014 EXECUTIVE SUMMARY
This environmental audit (EA) was carried out with strict adherence to the guidelines and regulation of the National Environmental Standards and Regulations Enforcement Agency (NESREA) in particular, NESREA Act, Section 7 (a) which vests in the Agency the responsibility to enforce compliance with laws, guidelines, policies and standards on environmental matters; Section 7 (j), that empowers the Agency to enforce environmental control measures through registration, licensing and permitting systems; Section 7 (k) of the Act that empowers NESREA to conduct environmental audit and establish data bank on regulatory and enforcement mechanisms of environmental standards other than in the oil and gas sector; Section 8 (k) of the Act also empowers the Agency to make Regulations, one of which is the Regulations S. I No 29, that requires existing industries to undertake environmental audit and submit reports of such every three (3) years. Desirous of complying with extant environmental laws and regulations Larrabee enterprises appointed MESSR PREPRA NIGERIA LTD – a NESREA accredited consultant to conduct the audit. In order to evaluate the impact of the activities of Larrabee, an assessment of the location in terms of compatibility and of the processes and housekeeping of the factory was undertaken. This initial contact ensured management consent and selection of audit team from the company. Standard questionnaire was administered to the management and key staff to obtain information that was used in the facility inspection as well as examination of records and documents of the company. The main activity in Larrabee enterprises limited is the conversion of animal hides and skins into leather which results in considerable quantities of several varieties of waste products and the tanning industry has the unenviable reputation of being one of the evil-smelling industries. With the expansion of settlements in the fringes of industrial layouts the problem is becoming more acute. Thus efforts are being made especially through vigorous enforcement of laws by NESREA to limit or eliminate as much as possible the discharge of polluting materials into the atmosphere. Tanning of hides and skins involve considerable use of water, either to cleanse them or in the form of process liquors during the various unit processes. Generally, a tannery can contribute to problems of health hazard by (i) causing depleting of oxygen in water where it is discharged, thereby removing the dissolved oxygen required by fish and other aquatic organisms for respiration, (ii) leading to high concentration of salts and possible formation of metal sulphides which are very harmful to both human beings and animal (iii) causing bacteriological pollution by pathogenic organism. 10
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This Audit exercise indicated that the operation of Larrabee tannery will result in short and long term adverse impact to the environment as well as nuisance to the community especially from waste water which is by far the most dominant waste product. Thus various strategies for treating the wastewater have been proffered as well as to minimize the generation instead of concentrating treating them. Further measures in which the wastewater can be reused directly subject to the guidelines of NESREA have also been suggested. In addition, suggestion were made in the report that will ensure that resources are used appropriately and efficiently; informed decision making; encourage and provide opportunities for public participation; a basis for ongoing environmental management through the use of monitoring; protection of human health and safety; avoiding irreversible changes and serious damage to the environment; safeguarding valued resources, natural areas and ecosystem components among others.
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1.0 CHAPTER ONE: INTRODUCTION 1.1
BACKGROUND
Environmental protection is considered the most important consideration for sustainable development. Consequently, globally, environmental regulatory agencies now embrace comprehensive, multi-statute solutions to facility permitting, compliance and regulatory development issues. In relation to organization’s activities, sustainable development involves meeting the current need of the organization while protecting recourses so that future generations are able to meet their needs. Environmental Audit (EA) is a systematic, documented, periodic and objective evaluation of how well organizations, management and equipment are performing with the aim of safeguarding the environment and human health in order to meet the requirements for sustainable development. It is designed to protect the environment with the aim of:
Assessing performance against a set of requirements or targets related to specific issues
Evaluating compliance with environmental legislation and corporate policies
Measuring performance against the requirements of an environmental management system standard
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Exploring the potential economic, social and environmental benefits that an improved performance can achieve.
The National Environmental Standards and Regulations Enforcement Agency (NESREA) is responsible for ensuring that all businesses and organizations comply with environmental laws that protect the environment and public health in Nigeria through;
The NESREA Act, Section 7 (a) vests in the Agency the responsibility to enforce compliance with laws, guidelines, policies and
standards on
environmental matters
Section 7 (j), empowers the Agency to enforce environmental control measures through registration, licensing and permitting systems.
Section 7 (k) of the NESREA Act empowers NESREA to conduct environmental audit and establish data bank on regulatory and enforcement mechanisms of environmental standards other than in the oil and gas sector
Section 8 (k) of the NESREA establishment Act also empowers the Agency to make Regulations. One of such made is the “National Environmental (Permitting and Licensing System) Regulations, 2009; S. I No. 29”
All the extant national sectorial environmental regulations require existing industries to undertake environmental audit and submit reports every three (3) years.
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Organizations that conduct environmental audit clearly demonstrate to its employees that it is committed to improving its environmental performances. In addition, it portends that the professionals within the organization are interested in environment issues and wishes to maintain environmental governance. Environmental Audit addresses regulators’ problem of obtaining effective dayto-day monitoring of regulatory compliance with limited resources. In addition, it aids in targeting enforcement actions because it more reliable differentiates between compliers and non-compilers. Environmental auditing has the longterm potential for improving relations between the regulators and regulated. Besides pursuing sanctions, NESREA can acknowledge and encourage corporations that demonstrate innovative approaches to environmental management through its NESREA GREEN MARK. 1.2
OBJECTIVES OF THE ENVIRONMENTAL AUDIT (EA)
The objectives of this EA include:
Generation of adequate environmental information assessment of facilities for the potential environmental risks that are likely to be caused by the operations to the facilities and immediate environs.
Achieving resources optimization and improved process performance.
Encouraging organizations to self- regulate their environmental practices and to increase their responsibilities to stakeholders and society.
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Ensuring compliance, not only with laws, regulations and standards, but also with company policies the requirements of the approved NESREA endorsed Environmental Management Plan of the organization as standard.
Enabling environmental problems and risks to be anticipated and responses planned.
Minimizing human exposure to risks from environmental health and safety problems.
TERMS OF REFERENCE OF THE EA
1.3
For the purpose of the mandatory Compliance Audit due every three (3) years; this audit assesses compliance of the Larrabee with criteria derived from:
National Environmental standards and Regulations enforcement Agency provided in sections 21 of the S.I.9 regulations of 1991 on National Environmental protection (pollution abatement in Industries and facilities generating wastes), EA Act No 86 of 1992 and 7 (a) and 7 (k) of the NESREA Act No 25 of 2007 and those that will come into force from time to time
Corporate or management policy of Larrabee
NESREA Approved facility Environmental management plan of Larrabee
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1.4 THE AUDIT CRITERIA The criteria used in environmental audits vary depending on the objectives of the audit process. Audit criteria considered in this study included but are not limited to:
Industry codes of practice
Specified organizational requirements (e.g. compliance with company environmental policy)
Environment protection Act
Environment protection regulations
Conditions of licenses, workers approvals and exemptions
Other applicable Federal/State / Local government -environment legislations
Standards, rules, orders, etc made under an act and having the force of law
International agreement such as, convention, protocol, and treaties which have been ratified by the government.
Conditions contained in facility permits
Codes of professional practice/ international code of conduct
Good environmental management
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1.5 SCOPE OF THE AUDIT The scope of this Audit exercise covers the following:
Evaluation of Larrabee existing Environmental management system
The existing environmental policy and objectives
Housekeeping and records
Existing strategies for environmental improvement
Larrabee compliance status with statutory laws and regulations
1.6 APPROACH AND METHODS This environmental audit was undertaken in three phases:
Pre – audit
On – site audit
Post – audit
1.6.1 PRE – AUDIT PHASE This is the audit preparation phase prior to visit by an audit team. It entailed.
Obtaining full management commitment for PREPRA NIG LTD to embark on the audit
Setting overall goals, objectives, scope and priorities for the audit
Selecting a team to ensure objectivity and professional competence
Sending out prepared pre-audit questionnaire to management and staff of Larrabee (see appendix1)
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Reviewing
October 1, 2014 background
and
operational
information
with
the
management of Larrabee.
Conducting initial site visit at the Larrabee facility
Reviewing audit plan and arranging logistics.
i)
Management commitment
A letter from the management of Larrabee to Prepra Nigeria to conduct the audit was duly signed by the CEO. This signaled the commencement of the audit. ii)
Team selection
The audit team was carefully selected and includes employees of the Larrabee and Prepra Nigeria. The team leader was a NESREA accredited consultant while the other team members have skills and knowledge relevant to the audit process. Each member of the team was assigned his/her role and responsibilities and pre-audit training was done to ensure that all the team members are adequately prepared for the task. In addition to other relevant information requested for in the questionnaire used (Appendix1), the following information were also collected by the team members:
Identifying
types
of
pollutants
and
waste
generation,
storage,
transportation, treatment and disposal as well as the general practice:
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Identifying requirements, regulations and limitations as applicable in the form of Permits and Licenses
Federal and State database relevant to Larrabee, such as, any nearby abandoned, inactive or uncontrolled hazardous waste sites; Industrial landfill; Municipal landfill; Solid waste sites and Drinking water sources
1.6.2 On site audit phase The purpose of the on-site audit phase was to collect verifiable evidence to determine whether audit criteria are being complied with. This entailed well defined and systematic use of checklists which started with: 1.6.2.1 Conducting opening meeting with factory manager and site personnel to:
Identify areas to be inspected
Outline procedures
Outline schedules
Identify records and documents to be reviewed during audit
Review health and safety requirement
Review how confidential data will be handled
1.6.2.2
Undertaking a review of relevant documents such as:
Corporate or/and management policy
NESREA endorsed Environmental Management Plan (EMP)
Management system documentation 19
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Operational procedures and records
Records (inventory, utility, monitoring, transportation, training)
Environmental monitoring/quality records
Correspondence on environmental committee/team meeting minutes
Previous environmental audit report (if available)
1.6.2.3 Conducting staff interview to obtain information on actual practices; awareness level; expectations and possible suggestions through :
Identifying key facility personnel
Scheduling ahead of time, meeting in work areas
Confirming interview time
1.6.2.3
Conducting detailed on - site inspections with the relevant audit checklist
This exercise was conducted to investigate the presence of sensitive sites within or n the neighborhood of the Larrabee factory that are capable of impacting on the data collected such as the nature of the past and present usage of the factory; nature and operations in adjourning properties - type and use past and present; above ground storage tanks ;Air sources mobile and stationary; Presence of Asbestos; Boilers usage; Contaminated sites; Drinking water quality cross connections; Discharges to groundwater; Neighboring wetlands and waterways protection; PCB containing transformers and/or other PCB regulated equipment; Sewage and septic system discharges etc. 20
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1.6.2.5 Collecting samples for Analysis 1.6.2.5.1 Procedure for collection of water samples Samples of wastewater representing the existing conditions in the Larrabee tannery were collected from effluent pit every day, over a period of seven days in suitable polythene containers with screw cap and stored in a refrigerator where immediate analysis was not possible. Samples (250ml) meant for the estimations of biochemical oxygen demand (BOD) sulphide were collected separately in two glass bottles stoppers. The dissolved oxygen and sulphide were fixed on the spot by the addition of winker reagent (MnSO4 followed by alkine-iodide-azide) and zinc acetate respectively. Since the components of the liquor undergo significant and unavoidable changes on storage, composite samples could not be used. 1.6.2.5.2 Evaluation of the quality of waste water Due to the complex nature of the wastewater and in view of the specific requirements relating to NESREA guidelines, the present work is based on the examination of different parameters as follows: 1.6.2.5.3 Measurement of temperature, pH and conductivity Wherever possible the temperature and pH of the samples were determined on the spot, the measurements of pH were conducted using the PH Meter (Philips
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PW 9418). The electrical conductivity was measured with the Griffin conductivity bridge. 1.6.2.5.4 Determination of total solids, suspended , Dissolved solids and Total ash The methods for the determination of solid used is that of Hanson (Hanson,1973). The term’ Total ash’ is a measure of the total mineral content and was determined by the method prescribed by the society of leather technologists and chemists(Soc. Leath,Tech.Chem.,1965). Other characteristics were estimated on the aliquots of the samples (100ml) obtained after removing the suspended solids by filtration. Estimation or chloride and total nitrogen were carried out using the argentimetric and ‘kjeldahl’ methods respectively. The amount of BOD was determined using the dilution method. Estimation of metals was carried out by using perkin-Elmer Model 306 Atomic Absorption Spectrophotometer and EEL Model A Flame Photometer. 1.6.2.5.5 .Conducting a material balance In the mass balance approach that was used in this study, each process needed to be clearly understood in terms of inputs and outputs. This was achieved by carrying out a mass balance assessment based on the simple principle that the total mass of material going into the process should equal the total mass going out i.e. Input – Losses = Outputs
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EXAMPLE OF INPUTS: raw materials – skins and various chemicals, packaging e.g pallets, plastic drums and containers, polythene, sacking and cardboards, consumable - e.g. gloves, aprons and ear defenders and utilities or services servicing each process e.g. water, steam, cooling water and compressed air. EXAMPLES OF LOSSES: waste materials such as packaging, liquids such as effluent or lubricants, air emissions and waste generated by the utilities or services OUTPUTS: the final product(s). The mass of inputs to the process in Larrabee should balance the mass of outputs as products, emissions and wastes, plus any change in stocks.
This
simply entailed the following steps.
Assembling unit process input and output information
Deriving a preliminary material balance for unit processes
Evaluating the material balance
Refining the material balance
1.6.2.6 Debriefing of the management on audit findings, recommended corrective actions This exercise involved meeting with the management in order to assess the observations made with a view to Identifying actual and/or imminent threats to health and the environments; Identifying actual noncompliance; Identifying 23
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noncompliance;
Identifying
and
discussing
information
gaps
Identifying and discussing unclear audit findings 1.6.2.7 Environmental monitoring data In evaluating environmental monitoring data the following amongst others were considered: That the sampling analysis
and procedures are appropriate and that
results comply with relevant national guidelines That the
steps taken to collect, review evaluate or verify data are
consistent with accepted best practices That management of data obtained in the course of audit process such
as: index, facility records, correspondence, include date, time, what, when etc. 1.6.3 Post audit activities The objectives are to produce an environmental audit report with audit findings and recommendations and to contribute toward formulation of an action plan for continuous improvement of operations of Larrabee. 1.6.3.1
Actions in post audit phase
Collation of information and follow up on outstanding issues
Evaluation of findings including outcome of material balance and impact evaluation of Larrabee process on the environment. 24
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Preparation of the draft audit report in the approved presentation format
Circulating draft audit report for comments to managements and audit team
Incorporating or resolving all comments
Preparation of an action plan with consultation with the management of Larrabee to incorporate the following:
A list of recommended actions in terms of increasing cost effectiveness in addressing the facility’s critical environmental issues.
Interim and long term targets/objectives and a time-table for achieving them for environmental improvement in the operation of Larrabee
An
indication
of
investments
and
other
resources
(human
and
information) that would be required at Larrabee without compromising commercial confidential information
Produce report for use of Larrabee and NESREA
Facilitate the implementation of action plan at the management level of Larrabee
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Evaluation of findings
The information gathered and data collected together with the overall findings of this Audit report will be reviewed in line with the extant regulations with the Larrabee management. The key rules in discussing the findings are:
The exact nature of the problems should be clearly stated.
Communicating the extent of the problem fully stating whether there is compliance or noncompliance.
Providing good management practices suitable to Larrabee.
1.6.3.3
Steps After analyzing the result of findings :
Prioritizing the problems/impacts and Allocating responsibilities/roles
Developing a plan of action and Assessing the effectiveness of plan and effect a change if it is not effective
Making all necessary agreed changes with facility management
and
Documenting and communicating the changes to the management of Larrabee 1.6.3.4 Implementation of the action plan Responsibilities needed to be undertaken according to unit and timeline for completion within the environmental action plan framework will be stated. 1.6.4 AUDIT PERIOD The audit was conducted between 14th September and 3rd October 2014. 26
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October 1, 2014 2.0 CHAPTER TWO: OVERVIEW OF LARRABEE ENTERPRISES
2.1 COMPANY PROFILE Table 1 Profile of Larrabee enterprises Limited
The Company
LARABEE ENTERPRISES LIMITED
RC. NO.
196655
Date of Incorporation
26/5/1992
Registered office Mailing Address
Plot 62, SHARADA INDUSTRIAL ESTATE, PHASE 111, P.O.BOX, 11344 KANO, KANO STATE.
Telephone No
234 (0) 934400 and 978446
Email
[email protected]
Ownership Structure
75% owned by Shour Family
Nature of Activity
TANNING
Installed Capacity
10,000 SKINS/DAY (WET BLUE)
Raw Materials
RAW ANIMAL SKINS, CHEMICALS AND WATER DIESEL,PETROL,LUBRICANTS, GREASE etc
Consumables Manpower:
Skilled Semi skilled
34 68
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2.2 LOCATION OF LARRABEE FACTORY Larrabee enterprises Limited’s tannery is located in Sharada Industrial estate phase 111, Kano, the most important and largest center of manufacturing activity in Northern Nigeria. The location of the Industrial estate within Kano metropolis is shown in Figure 1.
Figure 1 :
Location of Sharada Industrial Estate within Kano metropolis
The factory is sited between latitude 110. 56` 457and longitude 80. 29` 049. Based on the coordinates, the exact position of the factory is shown in Plate 1 as extracted from Google earth. The site of the land in which the factory is located consists of two plots of land covered by C of O No. LKN/1ND/82/36 covering an area of 0.735 hectares and C of O No LKN/IND/82/3 covering 0.733 hectares, thus the factory occupies a total area of 1.468 hectares. More 70% of the area 28
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of the factory is built up. All structures on the premises have been approved by Kano urban planning development authority (KNUPDA). 2. 3 THE PROCESS TECHNOLOGY Tanning is the process of treating animal’s skins to produce leather, which is more durable and less susceptible to decomposition. A tannery is the term for a place where the skins of animals are processed. It can be performed with either vegetable or mineral methods. 2. 3.1 Raw materials for the Tanning industry
Animal skins
a) Wet – salted Goat skins b) Wet – salted Sheep skins
Chemicals
a) Sodium chloride b) Sodium sulphide c) Chrome d) Sulfuric Acid e) Ammonium sulphate f) Caustic soda g) Soda Ash h) Ammonium liquor i) Dyes 29
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j) Bactericides k) Fungicides l) Formic Acid m) Enzymes n) Syntans o) Synthetic oils p) Vegetable oils q) Lacquers r) Pigments s) Binders (acrylic and non-acrylic) 2.3.2 The tanning process The first stage of the leather production begins with the collection and sorting of raw skins – normally supplied by designated agents to the companies warehouse. Plate 2 shows sorted raw sheep skins in the company’s warehouse Tanning involves four stages as indicated below: 2.3.2.1 Curing Preparing the skins begins by curing them with salt. Thus the skins form the abattoirs are wet-salted before being transported to the company. Curing is employed to prevent putrefaction of the protein substance [collagen] from bacterial growth during the time lag that might occur from procuring the skins to
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when it is processed. Curing removes excess water from the skins using a difference in osmotic pressure. The moisture content of skin is greatly reduced. In wet- salting, skins are heavily salted, then pressed into packs for about 30 days. In brine-curing, the skins are agitated in a salt water bath for about 16 hours. Generally, curing substantially reduces the chance of spoilage by bacteria. Curing can also be done by preserving the skins at a very low temperature. In Nigeria the only form of curing is wet-salting. 2.3.2.2 Beam-house operations The steps in the production of leather between curing and tanning are collectively referred to as beam-house operations. They include: soaking liming, removal of extraneous tissues (un-hairing, scudding, and fleshing), de-liming, bating, drenching and picking 2.3.2.3
Soaking
In the process known as soaking, the hides are soaked in clean water to remove the salt left over from curing and increase the moisture so that the hide or skin can be further treated. 2.3.2.4
Liming
After soaking, the hides and skins are taken for liming which is a treatment that involves the addition of sharpening agents like sodium sulfide, cyanides, amines etc. The objectives of this operation are mainly to: 31
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Remove the hairs, nails and other keratinous matter. Remove some of the inter-fibrillary soluble proteins like mucins. Swell and split up the fibers to the desired extent. Remove the natural grease and fats to some extent Bring the collagen in the hide to a proper condition for satisfactory tannage. The weakening of the hair on the breakdown of the disulfide link of the amino acid is called cystine, which is the characteristic of the ketarin class of protein that gives strength to hair and wools (ketarin makes up 90% of the dry weight hair). The hydrogen atoms supplied by the sharpening agent weaken the cystine. To some extent, sharpening also contributes to un-hairing as it tends to break down the hair protein. 2.3.2.5
De-liming and Bating
The pH of the collagen is brought down to a lower level so that enzymes may act on it in a process called de-liming. Depending on the end use of the leather, skins may be treated with enzymes to soften them, a process called bating. 2.3.2.6
Pickling
Once bating is completed, the hides and skins are treated with a mixture of common table salt and sulfuric acid, in a case a mineral tanning is to be done. This is done to bring down pH of collagen to a very low level so as to facilitate the penetration of mineral tanning agent into the substance. This process is called picking. The common salt penetrates the skins twice as fast as the acid 32
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and checks the ill effect of sudden drop of pH. The pH is very acidic when the chromium is introduced to ensure that the chromium complexes are small enough to fit between the fibers and residues of the collagen. Once the desired level of penetration of chrome into substance is achieved, the pH of the mineral is raised again to facilitate the process. This step is known as Basification. In the raw state chrome tanned skins are blue in appearance and are therefore referred to as Wet Blue. Chemicals used in tanning include chrome, salts, sulfuric acid, ammonium sulphate and bactericides. 2.3.2.7
Retanning
The wet blue is selected and shaved to specified thickness often determined by the final product to be used and subsequently moved back to the drum for retanning. Re-tanning is the process of using oils and vegetable extract to convert the skin into leather. The re-tanned leather is referred to as crust and it is often colored depending on the requirement. The crust is now complete leather and can be finished to various formats by the spray of pigments and lacquers. Chemicals used in retanning includes, dyes, formic and sulfuric acids, fatliqours and Syntans For finishing the main chemicals are binders of different make i.e. acrylic and non-acrylic, pigments and lacquers The stages can be summarized as follows:-
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Preparation for Tanning => Tanning => Re-tanning => Finishing In addition to skins and chemicals other materials that are required in a tannery like Larrabbe include water, lubricants, fuel, diesel, packaging materials and auxiliary facilities such as power supply etc.
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3.0 CHAPTER THREE: BASELINE ENVIRONMENTAL ASSESSMENT 3.1
DESCRIPTION OF SURROUNDING ENVIRONMENT
The factory site is very firm, relatively level and well drained. Larrabee enterprises limited is bounded by Gongoni Industrial Enterprises, to the east, to the west by Dangote flour mills, to the north by Sani Brothers Wire industries and to the south by Northern plastics. The factory is located about 45 meters off- the main trunk A road that links Kano city with Challawa Industrial estate. Across the trunk C road are Angel spinning as well as loquat tannery. It is also located a few meters from the main rail line that connects Kano to the south is at the eastern part of the factory making it very accessible. The factory is sited within an area
demarcated for medium to heavy industrial operation. The factory covers an area about 1.468 hectares of land. 3.2 EXISTING ENVIERONMENTAL MANAGEMENT SYSTEM 3.2.1 Environmental Policy of Larrabee Enterprises Limited The realization of the legal requirement to protect the environmental as well as the consciousness of the company to protect the health of its employees as well as the community in its vicinity led the company to initiate a company – community relation in order to come up with an enduring environmental policy. To ensure the actualization, the company engaged a NESREA accredited
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environmental consultant Messr- PREPRA NIGERIA LIMITED to lead the committee and come up with an environmental policy. The result of these consultation resulted in the adoption of an environmental policy by Larraabee enterprise limited with the vision and mission as : Vision ------ to be a producer of high quality leather products with an enduring commitment to preserving and protecting the environment ----------Mission -------- protecting and preserving the environment for future generation through commitment to training, creating awareness to staff and community and deploying the best technologies at all times to meet the challenges of a great changing world --------------The main objectives of the environmental policy adopted by Larrabee are: i) To maximize resource utilization and reduce waste ii) Fully comply with all applicable environmental protection regulations iii) Minimize damage to the environments from its operation iv)To use the best technology at all times
The environmental policy of the company is implemented through the environmental monitoring plan of the company that was submitted to
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NESREA. The EMP structured the implementation of the company environmental plan through the following plans: 1) Development of a company environmental policy 2) Environmental Management Implementation plan 3) Environmental Monitoring plan 4) Contingency plan 5) Safety plan 6) Risk assessment and Emergency response plan 7) Environmental management plan review 8) Reporting plan 3.2.2 IMPLEMENTATION OF THE EMP Larrabee enterprises limited have established an environmental and social monitoring unit that ensures implementation of the environmental management plan. The unit is led by a project manager and consists of staff members of Larrabee enterprises limited and a representation of the community. The unit is responsible for ensuring that the overall environmental targets are achieved and that the environmental responsibilities and obligation of the EMP is satisfied. Also the unit coordinates the day-to-day monitoring of regulatory bodies. Because liquid effluent forms a great proportion of the waste generated and to comply fully with the legal requirement to have a primary treatment plant, 37
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Larrabbe enterprises established a waste water primary treatment plant with the waste water collection pond. As a practical demonstration of compliance to environmental regulation and care to the health and well-being of staff, Larrabee makes it mandatory for all staff to wear protective clothing at all times based on the recommendations. To ensure smooth implementation of the EMP environmental, the following plans are put in place;
Environmental Reporting
Staff training Plan
Emergency Response Plan
Emergency Response plan
Contingency plan
Safety plan
Plan Review
Environmental monitoring plan
3.2.3 COMPLIANCE WITH ENVIRONMENTAL LAWS AND REGULATIONS IN LARRABEE The following among others are laws and regulations that are applicable to the Larrabee enterprises limited
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Laws of the Federation of Nigeria 1990, Labor ACT CAP 198 Relating to general welfare to staff – Changing rooms, toilet facilities, compensation, safety and protective wares, pre-employment medical examination, casualization of labor, workplace policy on AIDS/HIV
Business premises registration LAW (CAP, 18) 1992 section 4(1) of Kano state Government
Hides and Skins premises license
Hides and skins buyers license
The hides and skins (Northern states)Regulations 1958 - Exporters license
Billboard fees local government edict section 40 (t)chapter 84,vol.01.2 of laws of Kano state of Nigeria 1991, as harmonized by (JIB) decree 21, 1998section 7 (5)
Public health act
Polluter fee
Section 1 (1) of Regulation S.I.8 of 1991
Section 3 (1) of Regulation S.I.8
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Section 17 of Regulation S.I.9
Factories Act CAP 126 LFN 1990
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October 1, 2014 4.0 CHAPTER FOUR: AUDIT FINDINGS
4.1 OBSERVATIONS AND EVALUATION OF GENERAL HOUSE KEEPING The following are the results of observations and data collected in respect of the operations of Larrabee enterprises. 4.1.1 Waste Generation from Larrabee operation The following are the wastes that are generated from the manufacturing process in Larrabee: Liquid waste
Waste water – effluent
Oil and greases
Solid waste
Trimmings
Fleshings
Dust from buffing
Plastic and cartons from packaging
Spent chemical residues
General sweepings
Gaseous waste
Ancillary dust and compounds from boiler and generators 41
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Noise
Sound from generators and machinery
In addition to the wastes generated from operation of Larrabee, other issues considered for evaluation include level of compliance to regulations, safety and welfare provision to workers. 4.1.2 IMPACT EVALUATION 4.1.2.1 Waste water disposal Wastewater effluent is the dominant waste generated and data collected indicated about 600,000 litres is generated at full capacity. The existing methods of waste water disposal presently being followed in Larrabee is by discharging waste water after primary treatment through the main drainage outlet and ultimately into Salanta river . This method of disposal has its attendant problems and much pollution is caused by uncontrolled discharges. Table 1 shows the analysis of wastewater of Larrabee and its comparison with NESREA standard for waste water from tanneries, showing clearly it is not up to 100% in compliance. Although a small volume of waste discharge into rivers is eventually broken down by micro-organisms especially if nitrogenous organic substances are present, many of the substances in the wastewater from Larrabee are resistant to bacterial action and the breakdown may be very slow. Consequently remedial measures must be put in place to comply with NESREA guidelines.
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Table 2: Comparison of Larrabee effluent analysis with NESREA standards Parameter
NESREA permissible limits
Temperature
Less than 40(0C)
Larrabee Effluent Analysis Results 28.0
Colour
Colourless
colorless
pH
6-7
8- 9.5
BOD5 at 20(0C)
50
1956
Total suspended solids
25
40
Total dissolved solids
2,000
3077
Chloride (as Cl-)
600
1090
Sulphate (as SO42-)
500
130
Sulphide (as S-2)
0.2
3.3
Cyanide (as CN-)
0.1
nil
Detergents (linear alkylate sulphonate as
15
31.5
Oil and grease
10
6.9
Nitrate (as N03-)
20
21
Phosphate (as PO43-)
5
50.7
Arsenic (as AS)
0.1
nil
Barium (as BA)
5
1.6
Turbidity
10
3
Iron (as Fe)
20
3.5
Manganese (as Mn)
5
0.20
Phenolic compounds (as phenol)
0.2
1.12
Chlorine (free)
1.0
16.3
Cadmium (Cd)
Less than 1
0.1
Chromium Trivalent and hexavalent
Less than 1
N/A
Copper
Less than 1
N/A
Lead
Less than 1
N/A
Mercury
Less than 1
N/A
Nickel
0.5
N/A
Selenium
Less than 1
N/A
methylene
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Silver
0.1
N/A
Zinc
Less than 1
N/A
Total metals
3
N/A
Calcium (as Ca2+)
200
N/A
Magnesium (as Mg2+)
200
N/A
Boron (as B)
5
N/A
Alkyl mercury compounds
Not Detectable
N/A
Polychlorinated Biphenyls (PCBs)
0.003
N/A
Pesticides (Total)
Less than 0.01
N/A
Beta emitters (µc/ml)
10-6
N/A
Coliform (daily average)
400 MPN/100ml
N/A
4.1.2.2 Solid Waste disposal A substantial amount of sludge consisting of fleshing and solid residue from the liming made up of broken hair and other ancillary product such as plastic and paper from packaging, residue of various chemical and greases are the major constituents. A further component of the solid is dust from the buffing operation as well as general sweepings. Data indicated that about 1200kg of these wastes are generated daily from Larrabee operations. This is presently deposited on land surface within the factory and is eventually evacuated after the box made up of block is filled up. It is expected that when the waste slowly percolate through the soil and gradually undergo oxidation by soil bacteria it would result in the formation of harmless end products. However, it was observed that this practice requires large areas of land that the company currently does not have; it leads to bad smell; may contaminate underground water and can ultimately 44
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lead to poor agricultural productivity of the land. Also the polluted groundwater eventually flows into a drinking water well or river resulting in the spreading of waterborne diseases in the long run. Therefore remedial measures are required immediately 4.1.2.3 Compatibility The factory is located in Sharada industrial estate and is thus compatible with the existing approved land use of section 3.2 of the National policy on environment and Kano urban planning development authority requirement. 4.1.2.4 Fuel dump Larrabee has 11,000 and 5,000 litres capacity surface storages for diesel. Observation indicated that there is no oil/water separator. There is also no mechanism to prevent leakages from the tanks and no contingency plan against rupture of the tanks. 4.1.2.5 Cloakroom/Conveniences There is no cloak room especially for the female employees who are about 9 or 15% of the total work force. More serious is the fact that there is no separate toilet for women. 4.1.2.7 Safety signs There are no safety signs to warn staff and visitors within the factory.
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4.1.2.8 Soil Analysis
Soil samples in six different process areas of the factory to get a representative sample were analyzed in the laboratory to determine the characteristics of the soil. The analysis is shown in Table 3. The purpose is to use the data as baseline data for control/monitoring. Any change in the parameter determined to be caused by the operation will have to be ameliorated. Table 3: Soil Analysis within Larrabee factory Parameters Ph Temperature(°c) Moisture content (%) Base saturation (%) Organic matter (%) Oil and grease(mg/kg) Total hydro carbon(mg/kg) Nitrate(mg/kg) Phosphate(mg/kg) Chromium(mg/kg)
Values measured 8.0 23.9 1.9 85 1.3 0 0 63.1 3.6 0
4.1.2.9 Muster point There is no muster point within the factory 4.1.2.10 Fire extinguishes No Fire extinguishers and where they exist they have expired
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4.1.2.11 Illumination Illumination especially within the beam house is poor 4.1.2.12 Noise levels Noise level within identified units of the Larrabee plant were measured and compared with the NESREA permissible limits is shown in Table 4. Most units of the Larrabee factory is within the limit but the area in the vicinity of the generating room which also houses, the workshop and ETP are well above the limit and considering the presence of workers all the time in the area constitute a risk to the long term health of the workers.
Table 4 Noise level in some sections of Larrabee factory Sites within Larrabee NEAR THE GENERATOR HOUSE AVERAGE WITHIN THE FACTORY NEAR THE OFFICES NESREA STANDARD FOR INDUSTRY
Noise level 108dB 70dB 40dB 90dB
4.1.2.13Air Quality Air qualities within identified units of the Larrabee plant were measured as shown in Table 5. Most areas of the Larrabee factory has emission of gases within the limit but the observed variation not only indicated differences in the levels of air quality, but also potential problem that require attention especially the area in the vicinity of the generating room and the Boiler. 47
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Table 5 :Air quality in the Larrabee factory Sites within Larrabee Near the generator/effluent plant Near the offices
CO N02 S02 H2S CH4 2 3 0.67 1.81 0.11 0.2
0.3
0
0.1
0.0
4.1.3COMPLIACE WITH EXTANT REGULATIONS 4.1.3.1 Environmental Regulations
Section 7 (k) of the NESREA Act empowers NESREA to conduct environmental audit and establish data bank on regulatory and enforcement mechanisms of environmental standards other than in the oil and gas sector
Section 8 (k) of the NESREA establishment Act also empowers the Agency to make Regulations. One of such made is the “National Environmental (Permitting and Licensing System) Regulations, 2009; S. I No. 29”
All the extant national sectorial environmental regulations require existing industries to undertake environmental audit and submit reports every three (3) years.
Section 1 (1) of Regulation S.I.8 of 1991
Section 3 (1) of Regulation S.I.8
Section 17 of Regulation S.I.9l 48
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Larrabee is in compliance with the existing regulations as enumerated above by establishing a functioning effluent treatment plant and engaging a NESREA accredited consultant to prepare an Environmental Management plan (EMP) which has been submitted to NESREA and now an Environmental Audit. 4.1.3.2 Compliance to other regulations Larrabee is in partial compliance to most of the regulations, but needs to be aware of the laws currently in place that require adherence to. 4.1.4 SOCIO-ECONOMIC IMPACT Kano is known for its traditional leather and is famous in the tanning sub-sector with international reputation. The bulk of leathers produced in Kano are exported to Europe and Asia. Also, the artisanal producers convert finished leather for domestic finished leather goods markets.
Kano state has abundant
supply of skilled labor in the Tanning sector. This is obvious as commercial production for leather and leather products existed for many years in Kano. Leather and leather products are among the most widely traded and universally used commodities in the world. Already, the total value of annual trade is estimated at 1.5 times the value of the meat trade, more than five times that of coffee and more than eight times that of rice. In Nigeria, according to the Federal Ministry of Industry, Trade and Investment, leather has overtaken Cocoa
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as the second biggest foreign exchange earner for the country. A study by Chemonics International Inc. prepared for the United States Agency for International Development (USAID) in 2012 disclosed that Nigeria’s huge leather industry export worth $43.4 billion is begging for investors. According to the Report filed by Business Day, the industry is believed to be worth about $4.4 Billion for raw hides and skins, $14 billion in rough-tanned and finished leathers of all types and $25 billion for footwear with leather uppers. This indicates high exports potentials from the products. However, according to FAO current production in Nigeria is still less than 40% of the potentials that exist in the tanning sector. The aforementioned facts informed the decision of the Share-holders of Larrabee enterprises limited to launch themselves into the leather processing business.
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October 1, 2014 5.0 CHAPTER FIVE: RECOMMENDATIONS
5.1 GENERAL RECOMMENDATIONS
Larrabee needs to consider both the short and long term environmental issues arising from its operations with a strong view to sustainable development
Aesthetics and landscape of the frontage of the factory as well as the areas surrounding the effluent treatment and waste water holding tanks should be managed. A horticulturist should be engaged to enhance the beauty of the surrounding by planting flowers and trees that could also serve as a sink
There is the need to improve housekeeping especially around the effluent plant and water holding tanks
The solid waste collection should be segregated through the provision of bins of different colors with a view to recovery of such waste based on the principles of cradle to grave or life cycle approach
The importance of the Materials safety data sheet for the different raw materials especially chemicals should be made clear to the store keeper And other production staff
Larrabee must integrate environmental issues in its operation by introducing environmental accounting procedures to all its staff
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5.2 SPECIFIC RECOMMENDATIONS 5.2.1 Elimination of waste Ensure constant monitoring to repair leaking hose/ pipe, a faulty
valve on a tanning drum, and from disconnected pipework. Minor repairs can result in substantial water and effluent elimination. Lights/Generators to be switched off during lunchtime (one hour)
and shift breaks.
The lighting procedure can be a standard
practice by considering censor to control lighting in the toilets to increase savings. Steps be taken to ensure that empty cans are fully drained. This will
result in substantial reduction in spent chemical waste Leaking oil from the bearings of
drums and other equipment
should be monitored as well as the use of excess oil. 5.2.2 Reuse of waste on site
Collection of waste liquors from the soaking processes could enable the recovery of, 260,000lites of water; 6900 liters of paraffin for reuse (86% recovery) in subsequent batches.
5.2.3 Recycling of waste
Recycled polythene can be used as part of product packaging. On average, 527kg of polythene are used each week.
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5.2.4 Disposal after compaction drying, or other treatment
Currently, Solid following coarse screening of effluent are collected in open sumps. It is recommended now to transfer wet sludge to slotted cages where it is left to drain for a week. The dried sludge should then be transferred to a skip, which is sent to landfill. This will reduce the chance of land pollution by 80%
1,300 kg fleshings/week are generated from typical processing of 50,000 skins/week. In the past, these fleshings were collected in skips and disposed of to landfills. However, it is recommended that through compaction, fleshings can be now handled as a solid rather than a liquid waste eliminating hazard to soil and groundwater.
5.2.5 Retention/redirection This simply means determining uses for wastewater other than discharge. Examples of redirection include using “clean” wastewater or using nitrogen-rich wastewater as a fertilizer for plant grass areas. These approaches require close attention to regulatory requirements.
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5.2.6 Separation/concentration This should involve separating out solid or other materials from wastewater. Lowtechnology options include installing drain screen, setting basins, or systems to separate waste products out of wastewater before it is discharge. 5.2.7 Determination of specific water consumption Specific water consumption is the volume of waster used per unit of production, measured in m3 of product. Similarly, specific wastewater discharge is the volume of wastewater discharge per unit of production, measured in m 3 of products. Establishing these figures will allow the industry to compare the performance with benchmarks and that of other companies, regardless of company size and variations in throughput. As well as measuring how much water the industry is using, it is also useful to know how this consumption relates to the industry’s levels of production and therefore pointer to whether Larrabee is within industry limit or not. Above industry limit means the company is wasting money in water bill and discharging more than is necessary. 5.2.8 Produce by products from the waste generated Another best strategy that can be adopted in wastewater management is to look for wealth from waste. For example because of the process by which sewage collected, the solid content varies from 2-4%. They need to be preprocessed before use in a digester (biomethanation) for energy production. The
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biogas so obtained can be used in engines. Clean sewage based biogas has 400-1500 ppm of hydrogen sulfide. Mixed sewage based biogas has 1-3% hydrogen sulfide. Such a gas needs treatment before use in engines. 5.2.9 Reducing Noise level and Gaseous pollutants Generators should be sound proof and provided with acoustic devices to reduce high noise level. They should also be overhauled and serviced as at when due to minimize the levels of SO2 5.2.10 Compliance to all extant regulations Operations of establishments such as Larrabee are regulated and guided by local, state and Federal legislations that are either in force now or will be enacted from time to time. Larrabee enterprises limited must ensure that it is in compliance with all extant laws and regulations at all times. Such compliance is an indicator to integrity of the company. 5.2.11 General adherence to good management Larrabee must put in place good cleanliness of its premises; ensure that all staff are provided with appropriate uniforms and that they use them at all times; illuminations in all sections of the factory; Explicit signs in strategic sections of the factory; training of staff as enshrined in its EMP; Regular submission of effluent analysis as at when due etc
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6.0 CHATER SIX; FOLLOW UP ACTION PLAN 6.1 Completion and submission of EA 6.1.1 Submission of EA report SEPTEMBER – 0CTOBER, 2014, to i)
NESREA NWZ, Kano
ii)
NESREA Headquarters, Abuja
iii)
Kano State Ministry of Environment
6.1.2 Monthly effluent monitoring and sending results to NESREA and Kano state Ministry of Environment 6.1.3 Implementation follow on the management of the company’s EMP 6.1.4 Provision of adequate safety equipment 6.1.5 Provision of firefighting equipment in strategic locations of the factory identified 6.1.6 Awareness training for staff 6.1.7 Quarterly inspection 6.1.8 Establishment of quality assurance unit to ensure timely repairs to leaking oil/water pipes
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7.0 CHAPTER SEVEN: CONCLUSION This exercise examines the operations of Larrabee enterprises limited – a tanning plant as well as the compliance status of the plant with respect to environmental regulations and the contingency plans. Relevant general and specific regulations in these regards were proffered on the basis of the data collected during the exercise.
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APPENDIX 1 Environmental Audit Questionnaire 1.0
INDUSTRIAL IDENTIFICATION
1.1
Name and Address:
………………………………………………………………………………………………. ………………………………………………………………………………………………. ………………………………………………………………………………………………. 1.2
Type of Industry : -
Food, Beverages, Tobacco, Distilleries and Breweries
-
Textile, Paint, Tanneries, Pulp and Paper
-
Asbestos, Asphalt, Cement, Iron and Steel
-
Petrochemicals, Plastics, Cosmetics, Chemicals/pharmaceuticals and Allied Products.
-
Others (please state clearly). ……………………………………………………………………………………………… ………………………………………………………………………………………………
1.3
Year of Establishment: …………………………………………………………………………………………… …………………………………………………………………………………………… ……………………………………………………………………………………………
1.4
Number of Employees Total: …………………………………………………………………………………… Plant employees: ………………………………………………………………………… -
(indicate if you operate shift system) : Yes/No
If yes, specify shift periods: ………………………………………………………………………………………………… ……………………………………………………………………….. 58
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Number of Working Days Per Week:
……………………………………………………………………………………………………… ………………. 2.0
GENERAL SANITATION OF SURROUNDINGS:
2.1
How would you rate the general cleanliness of your surroundings? -
Above average
-
Average
-
Below average
2.2
How often do you clean your surroundings -
Once a week
-
Fortnightly
-
Monthly
-
Other
2.3
Are there any beautification plans in place i.e planting of trees and/or shrubs? Yes/No
2.4
If yes, how frequent is the landscape managed. -
Once a week
-
Fortnightly
-
Monthly
-
Yearly
-
Other
2.5
2.6
How would you rate the conditions of your drains and pipes? -
Good
-
Fair
-
Poor How do you keep the floors of your facility free from spent oil/grease and lubricants?
……………………………………………………………………………………………………… ……………………………………………………………………………………………………… ………………………………………………
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RAW MATERIALS:
Please list raw materials used and indicate quantities used per day. (a)
(b)
(c)
List all raw materials including
Average quantities used per day
Storage conditions
industrial chemicals
(Grms./ Kgs).
……………………………………….
………………………………….
………………………………
………………………………………..
………………………………….
………………………………
……………………………………….
………………………………….
………………………………
……………………………………….
………………………………….
………………………………
……………………………………….
………………………………….
………………………………
……………………………………….
………………………………….
………………………………
4.0
PRODUCTS:
4.1
Please list your products and indicate quantities produced per day.
……………………………………………………………………………………………………… ……………………………………………………………………………………………………… ……………………………………………………………………………………………………… ………………………………………………………………………………………………………
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INSTALLATION OF POLLUTION ABATEMENT EQUIPMENTS AND DATE OF INSTALLATION
5.1
List all types of pollution abating equipment you have installed in your facility.
……………………………………………………………………………………………………… ……………………………………………………………………………………………………… ……………………………………………………………………………………………………… 6.0
USE OF WATER
6.1
Please indicate source of water used in plant -
Well
-
Municipal supply
-
Surface water
-
Borehole
-
Other (specify)
………………………………………………………………………………………………… 6.2
How is the inlet water used and please specify volume used.
-
Process ………………………………………………………………………… liters/day
-
Cooling ……………………………………………………………………......... liters/day
-
Boiler …………………………………………………………………………… liters/day
-
Sanitation/ washing etc …………………………………………………………. liters/day
-
Other (specify) ………………………………………………………………….. liters/day
-
Total daily consumption …………………………………………… ………….. .liters/day 6.3
Please give a brief summary description of the processes involved in the use of water
……………………………………………………………………………………………… ……………………………………………………………………………………………… ………………………………………………………………………………………………
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……………………………………………………………………………………………… ……………………………………………………………………………………………… 6.3.1
Waste water
What are the means by which waste water is collected in your facility? (Please indicate volume). -
Combined for all effluents……………………………………………. liters/day
-
Separate for process water, domestic water, Rain run-off …………………………………………………………… liters/day
-
Other (specify) …………………………………………………………. liters/day
6.5.1 How many waste water outfalls are in your facility? ……………………………………………………………………………………………… 6.5.2 Indicate volume discharge for each outfall……………………………. litres/day 6.6 TREATMENT Do you treat your waste water
Yes/No?
If yes (specify)……………………………………………………………………………………… ………………………………………………………………………………………………… ………………………………………………………………………………………………… 6.7 if yes (specify briefly summaries steps undertaken by your establishment in treatment of waste-water before discharge) ……………………………………………………………………………………………………… ……………………………………………………………………………………………………… ………………………………………………………………………………………………….......
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If No, give reasons. ……………………………………………………………………………………………………… ……………………………………………………………………………………………………… …………………………………………………………………………………………………....... 6.8 Where do you discharge the treated/untreated water? - Into general sewers - Into receiving waters
(………………………….... liter/day) (……………………………. liter/day)
- Recycle -Reuse 6.9 What are your general observations on the quality of the receiving water (attach analysis log sheet of the receiving water) ……………………………………………………………………………………………………… 6.10 MONITORING Are samples of the waste stream analyzed? -
Yes
-
No
6.11 if yes please indicate frequency of sampling and analysis. - Weekly -Fortnightly - Monthly - Others (specify) …………………………………………………………………………………………………..
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6.12 Please indicate which effluent monitoring methodology is used? - USEPA - UK Department of environment method - NESREA (Nigeria Environmental Standards Regulations Enforcement agency) - WHO/GEMS (World Health Organization/ Global Environmental Monitoring system) - Others (Specify) 6.13 – Please attach your effluent analysis log sheet 7.0 SOLID WASTE 7.1 At what point along your production process do you generate solid wastes? ………………………………………………………………………………………………….. ………………………………………………………………………………………………….. ………………………………………………………………………………………………….. ………………………………………………………………………………………………….. 7.2 Do you have any waste segregation/sorting mechanisms or plans in place? - Yes …………………….
No…………………………..
7.3 If Yes, how? / If No why? ………………………………………………………………………………………………….. ………………………………………………………………………………………………….. ………………………………………………………………………………………………….. 7.4 What is the total annual industrial solid waste generated by your firm……………….. kg/day (give estimate)………………………………………….
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7.5 How do you manage your solid waste? Compression/compaction:………………………………………………………………… kg Recover from sorting:……………………………………………………………………. Kg Incineration:………………………………………………………………………………. Kg Store/bury in premises:…………………………………………………………………….. kg Others (specify)……………………………………………………………………………. Kg 7.6 How do you dispose of your solid wastes? ……………………………………………………………………………………………………… ……………………………………………………………………………………………………… 7.7 Where is the final waste disposal site? ……………………………………………………………………………………………………… 7.8 How do you treat and dispose of any corrosive, flammable or radioactive waste materials?.......................................................................................................................................... 7.9 How do you dispose of your expire raw materials and or products? ............................................................................................................................................................ ............................................................................................................................................ 8.0 GASEOUS WASTE: 8.1 List major air contaminants emitted by your facility. ...................................................................................................................................................... ...................................................................................................................................................... ...................................................................................................................................................... 8.2 Indicate the type of gaseous emissions abatement equipment in place. (Filter, scrubber, electrostatic precipitator, others). .………………..………………………………………………………………………… 65
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……………………………………………………………………………………………. …………………………………………………………………………………………….. 8.3 What is the maintenance schedule if any? …………………………………………………………………………………………….. 11. ENVIRONMENTAL AUDIT 11.1 Do you have any in-house environmental pollution monitoring unit? Yes ………………………………………. No………………………………… 11.2 Do you employ the services of a consultant to advice you on environmental issues from time to time? Yes …………………………………
No ………………………………….
11.3 Does your consultant have NESREA Accreditation? ………………………………………………………………………………………………… ………………………………………………………………………………………………… 11.4 When last did you carry out environmental audit on your facility? ………………………………………………………………………………………………… ………………………………………………………………………………………………… 11.5 Have you sent your audit report to NESREA office for review? Yes …………………………………
No ………………………………….
11.6 Which of the recommendations in the audit report have you implemented? Specify please…………………………………………………………………………… ………………………………………………………………………………………………… 12.0 HEALTH AND SAFETY 12.1 Number of accidents recorded yearly within the last three years. Year ……………………………..
No. of accidents ……………………………….
Year ……………………………..
No. of accidents ……………………………….
Year ……………………………..
No. of accidents ……………………………….
12.2 Number of fatalities Year ……………………………..
No. of fatalities ……………………………….
Year ……………………………..
No. of fatalities ……………………………….
Year ……………………………..
No. of fatalities ………………………………. 66
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12.3 Number and type of illness reported by workers in the last three years Type of illness ………………………. No. of staff………………………. Year ……… ………………………. No. of staff………………………. Year ……… ………………………. No. of staff………………………. Year ……… 12.4 State the type of safety warning signs in place. ………………………………………………………………………………………………… ………………………………………………………………………………………………… ………………………………………………………………………………………………… 12.5 List the safety gears you provide for your staff ………………………………………………………………………………………………… ………………………………………………………………………………………………… ………………………………………………………………………………………………… 12.6 How do you enforce usage of these safety gears? ………………………………………………………………………………………………… ………………………………………………………………………………………………… ………………………………………………………………………………………………… 13.0 GENERAL 13.1 What impact do the activities of your facility have on the immediate environment? ………………………………………………………………………………………………… ………………………………………………………………………………………………… ………………………………………………………………………………………………… ………………………………………………………………………………………………… 13.2 Has there been any complaints from the public on the activity of your facility? ………………………………………………………………………………………………… ………………………………………………………………………………………………… 67
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………………………………………………………………………………………………… 13.3 Any prosecution or warning notice and when? ………………………………………………………………………………………………… ………………………………………………………………………………………………… …………………………………………………………………………………………………
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