ENVIRONMENTAL & SOCIAL MANAGEMENT PLAN OF BIRRIN KEBBI SUB-STATION. for

Transcription

1 Public Disclosure Authorized Public Disclosure Authorized Public Disclosure Authorized Public Disclosure Authorized ENVIRONMENTAL & SOCIAL MANAGEMENT PLAN OF BIRRIN KEBBI SUB-STATION for PHCN-TCN Transmission Substation Rehabilitation/Re-enforcement Projects under the NEDP by ERSU-PMU August, 2009

2 Table of Contents 1.0 INTRODUCTION Project Background Project Locations ESMP Goals and Objectives INSTITUTIONAL ARRANGEMENTS Resourcing Responsibilities ESMP Guidelines 7 ESMP Audit Programme ESMP Implementation Organogram Details of Substation Rehabilitation/Reinforcement Work Substation Risk assessment and Management Project Potential and Associated Impact Identification Impact Characterization Impact Mitigation Measures DETAILED DESIGN FOR CONSTRUCTION & INSTALLATION Design Implementation Land take and Vegetation Clearance Foundation works/land/sand Filling & Surfacing Use of Public Access Road Sacred Archaeological Sites Hydrological Properties & Drainage Protection Pollution Control Air Pollution Water & Soil Pollution Noise Pollution Transport Operation Pre-mobilization of Vehicles Inspection & Maintenance Quality Assurance / Quality Control ENVIRONMENTAL MONITORING PLAN Monitoring Objectives 30 Monitoring Programme 31 2

3 7.2 Regulatory Compliance Plan Work, Safety & Health Plan Use of Work Permit Waste Management Plan Waste Handling Waste Type & Identification Waste Minimization & Reduction Waste Segregation Waste Disposal General Site Safety Plan Journey Management Plan Accident / Incident Management Plan Emergency Response Plan Consultation Plan Communication Plan Commissioning / Hand over Plan Decommissioning /Abandonment Plan 40 ALARP CBOS ERSU EPIC EER HSE JHA NGO PCB PHCN PMU PPE PRA RCP TCN WWI ABBREVIATIONS As low as reasonably possible Community Based Organisations Environment, Resettlement & Social Unit Engineering, Procurement, Installation and Commissioning Environmental Evaluation Report Health Safety and Environment Job Hazard Analyses Non Governmental Organization Poly Chlorinated Biphenyls Power Holding Company of Nigeria Project Management Unit Personal Protective Equipments Preparatory Rural Assessment Regulatory Compliance Plan Transmission Company of Nigeria Written Work Instructions 3

4 1.0 INTRODUCTION 1.1 Project Background This document presents the Environmental & Social Management Plan (ESMP) for the proposed Substation reinforcement/rehabilitation projects under the World Bank sponsored National Electricity and Gas Improvement Project NEGIP. The NEGIP by environmental screening is a category A project according to World Bank standards requiring a full environmental impact assessment for fresh subprojects and environmental audit for existing Project sites. The likely over all impacts of NEGIP considering the diversity of the scope are large scaled, covering a wide area, and affecting a large population and diverse habitats and ecosystems. This document then, is aimed at improving the viability of investing in the Substation rehabilitation/reinforcement from an environmental and social management perspective. By using this tool effectively, the anticipated potential environmental and social impacts associated with the substation projects will be minimized to the barest minimum thereby making the projects more sustainable. NEGIP is an Adaptable Program Loan (APL) aimed at assisting the Federal Government of Nigeria, through a combination of partial risk guarantees (PRG), for gas supply to generation stations and International Development Association (IDA) investments and technical assistance aimed at improving and developing the Nigerian power sector (substation reinforcement/rehabilitation, transformer repair shop and distribution facilities improvement etc). It follows a programmatic approach, and will consist of numerous investments broken into subprojects and guarantees over an extended time period. This ESMP provides the bases for managing the environmental and social issues involved with the implementation of the substation subprojects activities, by demonstrating how adverse and beneficial environmental as well as socio-economic and health effects will be managed in all phases of the project implementation. It therefore describes in specific terms how environmental, health and socio-economic commitments to be encountered in the Project implementations will be handled. 4

5 1.2 Project Locations These rehabilitation/reinforcement projects are to be carried out in the PHCN 330/132/33 kv transmission Substation in Birrin Kebbi in Kebbi State as part of the efforts to improve the Nigerian electricity transmission infrastructure. Most of the facilities at this station are old and (on paper) have out lived their life spans. More so, the technology used in manufacturing most of the installed equipments is old and have since been phased out by the manufacturers thereby making it almost impossible to source their spares. The fact that most of the transformers at this station were installed way back in 1976 reveals a real risk of PCB contamination in the event of Transformer oil spillage. This is so since the transformer oil then in vogue contained PCB until it was discouraged during the Stockholm convention of As from then, PHCN makes deliberate efforts not to use transformer oil containing PCB. Despite this, there are fears of these old transformers containing PCB since the oils therein were not totally drained at any particular point in time ESMP Goals and Objectives The Environmental & Social Management Plan of this aspect of the NEGIP project was developed in line with World Bank and Environmental Management System (EMS) ISO 14001:2004 Specifications; other national and international regulatory requirements, PHCN Environmental Policy statement and Health, Safety and Environmental & Social Management System as documented in the filed Project ESMF with the Ministry of Environment of the Federal Republic of Nigeria in The ESMF Objectives are to: Ensure that substation rehabilitation activities are carried out in such a way as to avoid harms to PHCN employees, contractors and all other stakeholders that may be affected directly or indirectly by the facility operations. Ensure that all hazards associated with the S/S rehabilitation and operations have all been properly identified and assessed. Barriers militating against the project established and material recovery and emergency measures put in place. Enforce safe and healthy procedures and practices in all operations and strive towards an incident free workplace. Ensure that appropriate trainings are given to staff and adequate and adequate equipment are provided to enable staff work in a healthy and safe manner. Maintain effective communication with all relevant parties and in particular communicating ERSU issues to the entire workforce. Demonstrate visible PHCN management commitment to ERSU issues. 5

6 Set clear ERSU targets to staff involved in the project. Carry out regular review of ERSU performance against targets. Ensuring that all operations are undertaken with proper regards for the environment, and strive to reduce environmental risk to a level that is as low as reasonably practicable. These objectives shall be achieved by: Ensuring compliance with all stipulated legislation on protection of the environment. Integrating social and environmental issues fully into the project development and operational philosophies. Promoting social and environmental awareness amongst workers and communities around the project sites. Rationalising and streamlining existing social and environmental activities to add value, efficiency and effectiveness to the Projects Ensuring that only environmentally sound procedures are employed during the different project phases and associated activities Continuous consultations with relevant regulatory bodies (FMENV, relevant State environmental protection agencies and other stakeholders), throughout the projects lifecycles. This ESMP shall remain a dynamic working tool through out the construction and operational life span of this Station. It may be reviewed with possible changes in regulatory regimes and in the event of new policies or guidelines from PHCN, WB or the Nigerian Environmental regulatory bodies. Periodic reviews and updating shall also be carried out throughout the project lifecycle, to incorporate better management systems and economic policies. ESMP Audit Programme This audit shall be conducted on regular basis to monitor compliance with the project ESMP. The scope will cover the major project activities including the overall requirements throughout the life of the project. PHCN performance towards meeting these requirement will be assessed. Generally, the audit programme will be conducted bi-annually during construction and at start up and every five (5) years during operations. The findings from these audits will be reported to the site ERSU Manager which will in turn pass it on to the PHCN management for corrective action plans which will develop a systematic follow up for performance improvement. 6

7 2.0 INSTITUTIONAL ARRANGEMENTS 2.1 Resourcing Environment, Resettlement and Social Units will be set up in this Substation. A site ERSU Manager shall be responsible for all ERSU-related matters throughout the project period and after during project operations in order to ensure compliance with environmental regulatory policy standards. For effective project implementation, the site ERSU Manager shall work in liaison with the Contractors Engineers & Environmental Officers, and TCN site Engineers to form the Project Management Team (PMT) and will be reporting directly to the Project management Unit of PHCN during the construction period and after to TCN during operations period. The Project implementation Organogram defining the line of Communication in the proposed Substation rehab/reinforcement (NEGIP) Project is presented below. Responsibilities Power Holding Company shall retain the primary responsibility of ensuring that environmental and social commitments are met throughout the project lifespan. The company shall establish a schedule of responsibility and improvement on matters relating to social and the environment. Environmental and social issues shall be seen as a line of responsibilities for which all levels of personnel are accountable as stated in the PHCN Environmental Policy Statement: ESMP Guidelines The detailed preliminary ESMP guideline developed to cover the entire phases and activities of the proposed NEGIP Project including responsibilities for implementation are presented in the Table below. 7

8 PHCN - PMU Site ERSU Manager Contractor/PHCN Project Mgt. Team (PMT) Environmental Officer Site HSE Officer Site Engineers Figure: Project Implementation Organogram 3.0 DETAILS OF THE SUBSTATION REHABILITATION/REINFORCEMENT WORK Rearrangement of 330kV switch yard Overhauling of the old 2 x 90 MVA 330/132kV transformers Overhauling of 2 x 30 MVA transformers with associated switch gears. Overhauling of 330kV, 132kV and 33kV circuit breakers Overhauling of 330kV, 132kV, and 33 kv isolators and earth switches Construction of new 33kV feeders Overhauling of Protection and Control Scheme of the substation Supply and installation of 1 x 150 MVA 330/132/33kV transformer Supply and installation of 2 x 60 MVA 132/33kV with associated switch gears Relocation of the old 33kV switch yard. In view of these activities, if proper management of the social, environmental, health and safety issues are not taken care of, the projects might not be as sustainable as required 8

9 according to the World Bank standard. It is based on this that this ESMP becomes very necessary. This ESMP is therefore designed to address the environmental and social impacts that might arise from the rehabilitation activities at this Transmission Substations. It will also proffer solutions to the lingering environmental issues like house keeping, social issues that may arise during the relocation of the old 33kV switch yard, oil spillage and proper disposal of scrap materials and spent transformer oil stored in drums around the store house, and also put in place a well trained Environment, Resettlement and Social Unit (ERSU) that will ensure strict compliance with World Bank, PHCN, Nigerian and other International environmental policy standards on the day to day running of the PHCN owned Substations. 4.0 SUBSTATION PROJECT RISK ASSESSMENT AND MANAGEMENT For any Projects of this nature, Risk management is an integral part of the project execution. The risks related to these projects execution and operations were identified by a structured approach during the project planning stage. Risk assessment visits by ERSU/Safeguard specialists were conducted in advance of implementation activities to allow for risk resolution without work interruption during implementation. Results of the risk assessments and the associated risks reduction measures were evaluated and documented by the PMU-ERSU and appropriate levels of the TCN site management staff in the affected substations. This document therefore is a product to be used for reducing project risks to an acceptable level at a reasonable cost to TCN. Upon project completion, all other unforeseen risks and their associated resolutions shall be documented for handover to the site operations personnel who will take over the Project and continue the operations of the completed facilities. The responsibility of risk management for these projects during implementation shall lie with both the Project Management Team (PMT) comprising of the PMU, the rehab Contractors and the TCN Site management. The environmental and social monitoring by the PMU-ERSU will reveal if the Contractor project implementation processes are being successful. The majority of the workers involved in the construction phases of the project will be Contractors staff, therefore Contractor will pay particular attention to applying appropriately controlled mitigation measures for their work. Contractors shall ensure that their HSE system are in line with this ESMP Guidelines. The Contractors working with Job specifications developed by PMU-ERSU will have direct responsibility for executing 9

10 the work using sound engineering fabrication, installation and commercial practices while maintaining adequate controls. The designs will take into account applicable Nigerian environmental laws and regulations, and in the absence of such, generally accepted industry standards shall be used. The Contractors will develop operating manuals and appropriate documentation regarding the proper operation and maintenance of the facility for approval by PMU-ERSU. This data will be provided to the PMU in a timely manner that facility-specific training can be given to the concerned personnel prior to start-up. Details of what is contained in the Contractors environmental manuals will be used by the ERSU in monitoring the job of the Contractors. 4.1 Project Potential and Associated Impacts The potential and associated impacts of the NEGIP Sub-station rehabilitation/reinforcement project is based on observed issues during the risk assessment visits to the Substations and the FMENV sustainability criteria. The visit to the Birin Kebbi Substation revealed the following: 1. That the store house and boundary of the switch yard are littered with scraps material of different kinds and also with abandoned 1 x 90 MVA transformer and several parts of circuit breakers that were removed during maintenance and also spare equipments kept in the open. Also there are about 75 drums containing spent transformer oil which are scattered around the store house 2. There are evidences of Transformer oil spillage around the leaking 15 MVA and 30 MVA transformers and also around where the burnt 13.8kV Reactor is kept and considering the age of the transformers and the reactor there is tendency of PCBs contamination in this substation. 3. Environmental management at these stations is generally poor as a result of drainage system, no particular order what so ever in the manner of attending to oil spillage, soil/under water contamination, and scrap management within the Substation premises. 4. Staff are not generally aware of the hazards of PCB in transformer oil hence they allow the leaking transformers to leak day in day out and Staff use it for washing hands after repairs and also as weed killers within the Stations. 10

11 5. There is a very serious drainage problem in this substation and threatening erosion problem on the transmission towers. 6. There are no Units properly established to take care of the Environmental, Social & Occupational Health and Safety matters in these Stations. 7. Usage of Personal Protective Equipment is lacking because they are not available in the store. 8. Routine cleaning and maintenance of equipments are not properly taken care of hence there are, dusts and dilapidation of equipments that are still in service as a result of lack of proper house-keeping The nature and duration of the various impacts of the project activities on the ecological components were identified as follows: 4.2 Impact Characterisation In order to further describe the nature and duration of the various project activities on the biophysical and socio-economic environment, the identified impacts were further characterised as direct / indirect, beneficial / adverse, normal / abnormal, short-term / long-term, reversible / irreversible, cumulative and residual. Beneficial Impacts: these are impacts that would produce positive effect on the biophysical or socio-economic environment. Adverse Impacts: These are impacts that may result in: Irreversible and undesirable change(s) in the social and/or biophysical environment; Decrease in the quality of the biophysical or social environment; Limitation, restriction or denial of access to or use of any component of the environment to others, including future generations; and Sacrifice of long-term environmental viability or integrity for short-term economic goals. Direct Impacts: these are impacts resulting directly (direct cause-effect consequence) from a project activity. Indirect Impacts: these are impacts that are at least one step removed from a project activity. They do not follow directly from a project activity. 11

12 Normal Impacts: these are impacts that will normally be expected to follow a particular project activity. Abnormal Impacts: An impact is considered to be abnormal when it follows a project activity as against sound predictions based on experience. Short-term Impacts: these are defined as impacts that will last only within the period of a specific project activity. Long-term Impacts: these are impacts whose effects remain even after a specific project activity. Reversible Impacts: these are impacts whose effects can be addressed on application of adequate mitigation measures. Irreversible Impacts: these are impacts whose effects are such that the subject (impacted component) cannot be returned to its original state even after adequate mitigation measures are applied. Cumulative Impacts: these are impacts resulting from interaction between ongoing project activities with other activities, taking place simultaneously. Incremental Impacts: these are impacts that progress with time or as the project activity proceeds. Residual Impacts: these are impacts that would still remain after mitigation measures have been applied. Table 4.1: Characterised Potential and Associated Impacts of the Proposed Substation Rehabilitation/Reinforcement Project of NEGIP Project Activities & Environmental Aspects Mobilisation of personnel, materials and equipment to project site Potential and Associated Impacts Risk of road accidents from increased vehicular movement on local roads and damage to the road by heavy vehicles to be used Character of Impact Adverse, direct, normal, reversible, cumulative 12

13 Preparation of the Equipment bases clearing at construction points, within the Substations and necessary point along the access roads Fuel Storage Foundation for the transformers and associated equipment Socio-cultural conflicts due to differences in customs of migrant worker and local residents Changes in demographic pattern/disruption of socio cultural pattern Introduction of communicable diseases (STDs, HIV, hepatitis b & c, TB & gastrointestinal) into the project communities Air/noise pollution from increased vehicular movement Damage to lawns within the Substations and also alteration in the stone chipping layers covering the Substation switch yards Loss of business hours and disturbance of residents and staff along the access routes during mobilization Employment of local labour De-vegetation/loss of vegetation at construction points. Soil/groundwater contamination from accidental leak or spill of stored fuel and transformer oil at camp/construction sites Soil erosion, dust and accident due to falls and damage to vegetation/alteration in the gravelled substation switch yard. Adverse, direct, abnormal, shortterm, reversible Adverse, direct, normal, reversible, cumulative, residual Adverse, direct, normal, shortterm, reversible, cumulative, residual Adverse, direct, abnormal, reversible, cumulative, residual and short term Adverse, direct, normal, short-term, reversible, Adverse, direct, normal, irreversible, longterm residual Beneficial, normal, long-term Adverse, direct, normal, short-term, reversible Adverse, indirect, normal, short-term, reversible, cumulative Adverse, indirect, abnormal, shortterm 13

14 Rehabilitation/Reinforcement of the Transformers and ancillary equipments Decommission and Closure Station Noise and vibration from construction equipment Respiratory tract infections due to inhalation of dust and toxic fumes during construction activities Risk of electrocution and burns (to onsite workers during construction) Induced secondary development in the substations (work camps/stores) surrounding by Contractor during construction activities Engagement of indigenous labour and supplies and stimulation of local economies Youths/community restiveness especially during recruitment of local labour Community restiveness during heavy vehicular movement due to road congestion and damages Decommissioning of old transformers, solid wastes and spillage of the transformer oil suspected to contain PCB Electric shock and severe burns to workers during decommissioning Impaired aesthetic resources due to visual presence of wastes and scraps Direct poisoning of vegetation/soil contamination due to uncontrolled application of maintenance, chemical/herbicide Adverse, direct, normal, short-term, reversible Adverse, direct, normal, short-term Adverse, direct, normal, short-term Adverse, direct, normal, short-term, reversible Beneficial, direct, normal, short-term, reversible Adverse, direct, abnormal, shortterm, reversible Adverse, direct, abnormal, shortterm, reversible Adverse, direct, abnormal, longterm, reversible Adverse, indirect, abnormal, longterm, irreversible Adverse, direct, abnormal, longterm, reversible, residual Adverse, direct, abnormal, shortterm, irreversible 14

15 5.0 ENVIRONMENTAL IMPACT MITIGATION MEASURES FOR THE SUBSTATION REHABILITATION PROJECT Below is the table showing the intended mitigation measures for the key environmental and social impacts of the NEGIP substation rehabilitation/reinforcement project. 15

16 Project Phase / Environmental Aspects Site 1.Preparation Critical Control Point Transportation vehicles Mitigation Measures Contractor trucks shall be ERSU Action Party Mobilisation of & routes properly Manager/PMT personnel, material serviced/maintained before and equipment to mobilisation project area Contractor shall mobilise heavy duty trucks carrying equipments in the night to avoid traffic delays/accidents Outriders shall be engaged when possible and used during mobilisation of heavy duty trucks and equipment. Radio/TV announcements shall be made to inform the general public of activities/movements Contractor shall engage and use traffic control wardens at strategic points on local roads Strategic road signs/warnings shall be placed on local roads PHCN shall enforce approved speed limits on local roads among its drivers and Contractors personnel 16

17 Local roads Work sites Recreational facilities Markets, etc. Contractor shall survey and make use of best road access to site and repair damaged road points/areas damaged as a result of the movement of their equipment to site Contractor shall educate its workers on the socio-cultural norms of the host communities so as to conform to laid down customs and norms of the local community Recreation areas should be avoided by vehicles carrying equipments as those areas are always busy and they may cause hold ups. The above situation applies to market places ERSU Manager/PMT ERSU Manager/Comm unity Relations Officer 17

18 Site Preparation Mobilisation of personnel, material and equipment to project area Site Preparation Vegetation clearing at construction sites Base campsite Prior to mobilisation, Contractor shall screen all personnel for communicable and other diseases Communities Contractor shall conduct a health and safety awareness for staff and host communities Contractor shall carry out periodic health screening for staff while on site and identified cases shall be promptly isolated for proper medical attention Operational Vehicles Contractor shall ensure that its operational vehicles are at optimal operating conditions Construction areas to Contractor shall limit be cleared vegetation clearing to minimum area required for the campsite, construction site and access roads Disturbed and unwanted areas at campsite, and access roads shall be revegetated with appropriate local species ERSU Manager/PMT / Community Relations Officer Site HSE Coordinator/ transport supervisor Site ERSU Manager/ Site Engineers 18

19 Project Phase / Environmental Aspects Site Preparation Fuel storage Construction Plinth for transformer bases and Installation of other related S/S equipment Critical Control Point Mitigation Measures Storage containers shall be Storage area periodically checked for leaks Operators shall be trained on safe fuel handling practice Containers shall be provided with secondary containment capable of holding 110% of its contents Within the Substations Contractor shall employ best engineering practice in the excavation of the pits and for ancillary facilities in order to avoid adverse alteration of the hydrological pattern of flow Dug up areas shall be promptly and properly restored Construction points Contractor shall maintain all construction equipment at optimal operating conditions in order to reduce noise and vibration Health and Safety at Contractor shall design and excavation points enforce workplace safety procedures at sites based on this hazard to prevent accidents Action Party Site HSE Co-ordinator Site HSE Co-ordinator / Site Engineers Site ERSU Manager HSE Co-ordinator/ Site PMT 19

20 Project Phase / Environmental Aspects Welding of materials, erection of transformers and Installation/operation of other S/S equipments Project Phase / Environmental Aspects Welding of materials, erection of transformers and Installation/operation of other S/S equipments Critical Control Point Mitigation Measures Welding/construction Specialized PPE shall be provided points and usage enforced during welding activities Worksites Contractor shall design work place procedures in line with standard industrial practice Specialised PPE shall be provided for all on site workers All pits/holes dug during construction works shall be appropriately filled. Critical Control Point Mitigation Measures Campsite Contractor shall develop comprehensive plan for location of secondary development Construction points Contractor shall ensure that its construction equipment are maintained and operated at optimal conditions to reduce emissions capable to air pollution Installation points Contractor shall design, enforce and maintain good work place procedures in line with industry standard and regulatory requirement on safety Standard work instructions for HSE critical activities shall be developed and enforced Action Party Site HSE Co-ordinator/ Site Engineers ERSU Manager/Site HSE Co-ordinator/ Site Engineers Action Party ERSU Manager/PMT Site HSE Co-ordinator ERSU Manager/Site HSE Co-ordinator/ Site Engineers 20

21 Point of mobilisation Prior to mobilisation Contractor ERSU shall screen all personnel for Manager/Site HSE communicable and other Co-ordinator diseases Contractor shall conduct a health and safety awareness for staff and host communities Recruitment point Contractor shall ensure that the ERSU content of the memorandum of Manager/Communi understanding between it and ty Relations Officer the host communities on employment are religiously followed Project Phase / Environmental Aspects Welding of Critical Control Point Transmission line Mitigation Measures Where transmission lines are to Action Party materials, erection be involved, Contractor shall Site HSE of transformers and maintain the selected route for Co-ordinator Installation/operation the transmission line (with of other S/S minimal interference with areas equipments of human activity) Adequate and automatic Site Engineers fault/damage detection system shall be installed where possible Personnel shall be trained on the detection/handling of such emergencies arising from shocks or accidental damages 21

22 Project Phase / Environmental Aspects Welding of materials, erection of transformers and Installation/operation of other S/S equipments Contractor shall install specialised fire detection/prevention equipment at the substation Staff shall be trained on emergency fire/explosion handling procedure Contractor shall design and maintain work place procedures in line with industrial standards Control rooms in the Adequate and automatic Station (substation) fault/damage detection system shall be installed Personnel shall be trained on the detection/handling of such emergencies arising fro accidental damages Critical Control Point Mitigation Measures Substation safety Contractor shall install automated monitoring system (CCTV) to check unauthorised entry Emergency response plan shall be put in place for such developments as sabotage/vandalisation Contractor shall use only trained and competent personnel for all maintenance works Maintenance personnel shall be provided with appropriate PPE Personnel shall be trained on handling of emergencies ERSU Manager/Site HSE Co-ordinator Site Engineers Site Engineers Action Party Site Engineer/ Site HSE Co-ordinator ERSU Manager/Site HSE Co-ordinator 22

23 Substation House Keeping Substation environment shall be properly maintained and kept in good healthy condition. Lawns must be planted with indigenous flower species and grassed accordingly Management shall maintain naturally low growing vegetation within the Substations Management shall explore the option of always using mechanical maintenance techniques For chemical maintenance option, Management shall employ selective herbicide application Site Management shall maintain appropriate gravelling level of the Switch Yards Equipment must be in sound working condition and cleaned as at and when due Used transformer oil must be disposed as appropriate in line with regulatory requirements Solid wastes must be disposed of by using appropriate waste disposal companies and in line with laid down rules ERSU Manager/Site HSE Co-ordinator 23

24 Project Phase / Environmental Aspects Critical Control Point Substation site location Mitigation Measures PHCN shall as much as practicable Action Party ERSU avoid locating Substations near Manager/PHCN market/city centres, tourist Engineers attractions and places of special value and interest to the people. Decommissioning / PHCN shall ensure that the ERSU Abandonment decommissioning and abandonment Manager/PHCN plan for the Substations and the Management proposed projects are implemented in details as contained in this document. 24

25 6.0 DETAILED GUIDELINES FOR THE SUBSTATION REHABILITATION/REINFORCEMENT CONSTRUCTION AND INSTALLATION This aspect of the ESMP is developed in such a way that it would be inserted in the Bid documents for the intending Contractors to know what is expected of them during the project implementation period. Based on their approved submission the PMU-ERSU will monitor their site activities. 6.1 Project Design & Implementation The design of the proposed Substation Rehabilitation Project of (NEGIP) is based on Power Holding Company/TCN Operations, Maintenance and HSE guidelines as well as relevant technical specifications in agreement with standard power and electrical industry practices. These philosophies identify relevant standards, codes, practices and specifications that apply to the technical/operating specifications to be used for the design, construction and operations of the proposed NEGIP Project. The guidelines also address controlling deviations from approved standards, codes, practices and specifications, and providing feedback to improved standards. 6.2 Land Take & Vegetation Clearance These Projects are to take place within existing TCN Substations and it is expected that there will be no land take except in any case of Substation expansion or for temporary access into the construction site. All clearing works at the construction site and access roads shall be carried out within a defined perimeters and only when and where necessary. Clearing of vegetation shall be kept to the minimum necessary to permit safe operations. Trees felled from site shall be re-utilized for the benefit of the substation/host communities. Areas cleared in excess of operational requirements shall be reinstated with indigenous topsoil and vegetation. 6.3 Foundation Works, Land / Sand Filling and Surfacing Work along access roads and construction site shall be carried out in such a manner that there is no damage or interference with existing water courses or drainage systems, utilities, structures, roads or other property of public or private, vehicular or pedestrians access, other than to the extent that is necessary for them to be removed or diverted to permit the execution of work within the defined operational perimeter. Any facilities disturbed or damaged directly or indirectly due to foundation works, site excavations, land/sand/gravel filling and surfacing activities shall be restored to the original condition. The clean up and restoration plan shall be in accordance with regulatory requirements. 25

26 If existing watercourses and drainage systems are required to be temporarily diverted to enable the works to be carried out, approval for such diversions shall first be obtained from the relevant authorities. The diversion shall be maintained while the work is being carried out and shall be re-instated, including the removal of any obstruction to hydrological flow as soon as practicable after work is completed. No excavated material or debris shall be permitted to enter existing drainage systems or water courses. Settling ponds or other approved means shall be provided, if necessary to ensure compliance to the requirements of the local authorities. 6.4 Use of Public Access Roads All transportation, construction/installation and surfacing works shall be executed in such a manner that will ensure that interference with the use of public roads is minimal. However, if operational safety demands the blockage of public roads, then the site HSE Coordinator may approve such operation only when temporary traffic control and diversion arrangements have been provided. Storage of litter/debris, tools and equipment in public or private roads shall be prohibited. Contractors shall develop road clearing strategies to ensure that public roads are kept clear, safe and passable throughout the duration of their job as they will not be permitted to cause any public nuisance. 6.5 Sacred / Archaeological Sites Agreement shall be made with Contractors and relevant authorities working on site to clearly demarcate areas of exclusion around existing sites of heritage and cultural value to the host community. Contractors shall not remove or relocate any of such sites in the course of project execution without notifying PHCN s representative who shall make necessary arrangements and obtain authorization from members of the affected community before such removal or relocation. 6.6 Hydrological Properties and Drainage Protection Contractors shall ensure that there will be minimal adverse environmental impact on the drainage pattern of the project area, and that all hydrological characteristics and qualities will be maintained at its present status or be improved upon. During excavation, construction/installation works, the Contractors shall where necessary ensure that the surface water flows on land or swamp areas are controlled 26

27 and if necessary channelled into temporary discharge pits. Such pits shall be located, designed and constructed in a manner that will minimize the potential threat of erosion. Muddy water and surface run-off from work sites shall be drained into suitable silt traps before discharge into rivers or creeks. The silt trap shall be of adequate size and regularly de-silted. Excessive site clearing shall be avoided and exposed surfaces shall be re-vegetated as soon as practicable to minimize erosion. 6.7 Pollution Control Air Pollution In operating equipment, Contractor shall utilize all practical methods and devices available in order to control, prevent and otherwise minimize atmospheric emissions or the discharge of air contaminants. Good engine efficiency of equipment and vehicles shall be adequately maintained. Indiscriminate burning of materials resulting from clearance from trees, bushes and combustible materials shall also not be permitted Water and Soil Pollution Pollution of surface water by wastewater, oil and other lubricants/ liquid wastes shall be prevented by proper management practices. Drainage and effluent water from the chemical/fuel storage and processing facilities shall be collected and treated to approved regulatory requirements of 10ppm oil in water using wastewater treatment plant to be installed before discharge. Contractor shall perform all excavation, construction and surfacing activities by methods that will prevent pollution of the soil media by accidental spills of contaminants, debris, and other objectionable pollutants. Regular checks shall be conducted on equipment to minimize minor lube oil and combustible leaks from engines. Safe distances and buffer zones shall be established between facilities, work sites and host communities/substation staff to reduce the impact of high noise levels from the facilities being reinforced or rehabilitated. 6.8 Transport Operations The Contractor shall manage all transport operations in line with the following guidelines in order to forestall accidents/incidents Pre-mobilization of Vehicles All vehicles to be used for transportation of equipment, materials and personnel shall be pre-mobilized by the site ERSU Manager. The pre-mobilization shall be conducted to confirm that the vehicles and the drivers have the necessary competence needed for the 27

28 journey. It shall also be confirmed during pre-mobilization exercise that a Job Hazard Analysis (JHA) has been conducted for the trip and that all recommended precautions (mitigation measures) have been adopted. 6.9 Inspection and Maintenance Procedures for Contractor Equipments In order to assist on maintaining the technical integrity of the facilities, a well defined inspection and maintenance management system will be put in place in order to ensure compliance with (safety) regulations. Contractor s maintenance programme shall deal with establishing the processes to develop and sustain necessary maintenance procedures. The system shall address identifying and classifying procedures required as to their impact on operating integrity, controlling deviations from procedures and updating of procedures to capture lessons learned. It will also address training and verifying competency for facility specific procedures. The maintenance system will include plans and procedures for: Normal maintenance (routine and breakdown maintenance performed by the maintenance technicians involved in the proposed project. Preventive maintenance (activities carried out at pre-determined intervals) Predictive maintenance (as initiated by facility condition monitoring and assessment Inspection (in accordance with a pre-defined programme and based on statutory and company requirements) 7.0 ENVIRONMENTAL AND SOCIAL MONITORING PLAN Contractor and the PMT shall strictly operate a monitoring programme that would lead to sustainable project-environment relationship. This will be strengthened with the occasional monitoring visits of the ERSU-PMU. The monitoring programme shall commence from site preparation through implementation to operation stages in order to keep track of the entire project activities and performance. The programme will provide information on impacts compared with prediction and by doing so provide advance warning of any adverse changes in both the ecosystem and socio economic development. 7.1 The main objectives of the monitoring programme are to: Ensure compliance with regulatory emission and discharge limits Monitor changes in existing physio-chemical, biological and social characteristics of the environment, compared to both the environmental baseline and predicted conditions 28

29 Ensure continual interactions and flow of information between Contractor and the stakeholders Determine whether any detected changes in socio- economic and environmental components are caused by the project or by other forces Determine the effectiveness of the control and mitigation/ enhancement measures and provide basis for recommending additional measures Ensure that the established transparent procedures for carrying out the proposed project are sustained Ensure sustenance of accountability and a sense of local ownership through out the project lifecycle. The programme is for the initial stages of the project. The monitoring frequency is subject to review after the first year to determine its effectiveness and possibly include other identified areas of concern. The ERSU-PMU shall ensure that the monitoring programme is fully implemented. The Environmental monitoring programme designed for the construction and operations phases of the project is shown in Table below. Table 7.1: Environmental Monitoring Programme for the proposed NEGIP Components Project Phase Impact Indicator Location Method of monitoring Biodiversity (Vegetation and wildlife) Air Quality Soil Site preparation and operation/maint enance phases Site Preparation, Construction/in stallation and Operation Phases Site Preparation, construction/ins tallation and Operation Abundance and diversity of native plant and animal species, presence of exotic plant species CO, SO X, NH 3, NO X, and HC PCB, HC, Heavy metals, & Hydrocarbon utilizing Fungi and Bacteria Survey and sampling within the S/S and access way corridor and within the communities along transmission route Sampling and measurement within the S/S Sampling and testing around the transformer locations and within the switch yard Duration/ Frequency During Site Preparation and yearly during operation phase Weekly during site preparation and construction yearly during operation phase During Site Preparation and Twice yearly during 29

30 Phases operation phase Surface Water Construction/in stallation and Operation Phases ph, Cond., TDS, BOD, PCB, COD, Turbidity, Oil and Grease etc. Sampling and in-situ testing of water from wells around the S/Ss and streams near the laboratory testing During construction/ installation and yearly during operation phase Noise Site preparation construction/ins tallation and operation phases Noise Level 90 db (A) Measurement around Substation and the adjoining host communities Weekly during site preparation and construction yearly during operation phase Community health Socioeconomic indices Employment pattern Compensati ons/homage Site preparation construction/ins tallation and operation phases All phases All phases All phases Common/prevalent diseases in the S/S & host communities Traffic flow, income levels, housing, trading activities, and social infrastructure Contractors/suppliers, part/full time Employment, skilled/unskilled labour recruitment Land take, accident victims, landlords/community relationship, leadership and governance Collection of data and statistics from Clinics and Hospitals within host communities Within host communities Consultations with community leaders and youths in host communities and review of Employment quota Consultations and review of MOU with host communities Yearly and or when necessary Twice yearly during project phase Yearly during project phases During construction phase and biannually during operation/maintena nce 7.2 Regulatory Compliance Plan A comprehensive checklist shall be developed in order to check every HSE-related regulations for the proposed project including those yet to come. The specific requirements of each of the regulators. Standards or codes shall also be clearly defined in the checklist. Project-specific compliance shall be interpreted and documented into a Regulatory Compliance Plan (RCP) which will be approved and then incorporated into the routine administrative activities. 30

31 8.0 WORK SAFETY AND OCCUPATIONAL HEALTH PLAN Operations within the work site shall be subject to government, industry and PHCN Policies guidelines. All PHCN and Contractor staff shall be well informed and trained on the HSE policies and guidelines. All facilities shall also be designed to enhance safety planning, and activities shall be executed within the confines of relevant legislation and stakeholders interests. PHCN/Contractors shall provide adequate health services as well as site first aid services for its workforce. The first aid services shall be extended to visiting personnel and casual workers. All construction activities shall be properly managed through careful planning and the applicable and relevant HSE policies and inclusive of the following: 8.1 Use of Permit-to-Work Job Hazard Analysis and toolbox meetings Use of appropriate PPE in designated areas Prohibition to drinking of alcohol during working hours and at work sites and facilities Prohibition to night trips Regular emergency drills Prohibition to smoking in fire hazards areas. 9.0 WASTE MANAGEMENT PLAN The manner in which wastes are handled, stored and disposed is dictated by the nature of the waste and this waste management plan takes into consideration the nature of all wastes that will be generated during the lifetime of the proposed project. The following objectives form the basis for the waste management plan of the project. Progressive reduction of wastes with the target to minimize overall emissions/discharges, which have adverse impact on the environment To meet the environmental requirements of FMENV and other national and international waste management as well as PHCN corporate waste management guidelines To establish, implement and maintain waste segregation aimed at enhancing recycling To ensure that PHCN and Contractors are responsible for effective waste handling and disposal process, which shall be monitored by relevant waste disposal authorities To ensure that waste management programme is in line with the provisions of the Environmental Management Programme of ISO

32 The standard for the plan are binding on all staff and Contractors involved in the proposed project with respect to the: Emission or release of pollutant and fugitive gases Discharge or spill of untreated liquid effluent on land and into surface water Discharge of solid waste on land and into surface water Generation of noise. 9.1 Waste Handling Guidelines For proper handling and disposal, wastes shall be well defined at source and the definition transmitted along with the wastes to the final disposal points. PHCN and Contractors personnel shall define and document all wastes generated in the course of work in a monthly waste stream report, which shall be used to track/monitor wastes generated from the Substations. Basic information that must be provided as a minimum for adequate definition of wastes include: 9.2 Waste type identification; The major categories of wastes envisaged from the Substation Projects are outlined as follows: Category/Definition Solid wastes This include felled vegetation/trunks, woods from crates, metals, papers, printer cartridges and other office services, domestic waste (waste generated from camp kitchens, packing materials, boxes and plastics) Liquid wastes: This include hazardous and non hazardous materials e.g. spent transformer oil waste generated from the non functional transformers and other operational waste generated from work construction sites e.g. lubes, lubricants, sanitary water, paints etc Gaseous wastes: This include combustion products from construction engines, SF6 gas used in the circuit breakers, welding gas, natural gas leaks etc Hazardous waste is any gaseous, liquid or solid, which due to quantity, physical, chemical or infectious characteristics have the potential to harm human health, environment when improperly handled, stored, disposed, transported or treated e.g. acids, lead, phenols, etc. 32

33 9.3 Waste Minimization / Reduction Waste minimization implies reduction to the greatest extent possible of the volume or toxicity of waste materials. The four principles of waste minimization process are - recycle, reduce, reuse and recover, shall be adopted as applicable. The key elements of the four waste minimization/management principles practices are outlined. Minimization Definition Reduce Process modification / design change Material elimination Inventory control and management Material substitution Improved housekeeping Reuse Chemical / Oil containers Reuse waste heat Recycle / Recover Recycle scrape materials Recycle paper Burn waste lubricating oil for energy recovery Recover oil from tank bottom Waste Segregation Waste segregation and characterization shall be carried out on wastes that are similar and may be combined to simplify storage, treatment, recycling and effective implementation of appropriate waste disposal methods. Wastes shall be segregated, preferably at source into clearly designated bins at strategic locations. Particular attention shall be given to the work area where a variety of wastes including fast food packaging shall be generated. The site HSE Coordinator shall be responsible for maintenance of the waste segregation scheme at the site. Waste Disposal All debris, spoil materials, and other wastes shall be cleared regularly from the site and dispose off at approved dump sites operated by designated waste disposal authorities. Instructions on material safety handling Data sheet shall be strictly adhered to and shall form basis for the disposal of wastes related to such products. Wastes in transits shall be accompanied and tracked by waste disposal notes. The note shall as minimum contain such information as date of dispatch, description of wastes, waste quantity, 33

34 container type, designated disposal site and method, consignee name, means of transport and confirmation of actual disposal time and date Waste management audit of facilities shall be carried out in consultation with the HSE Department of PHCN, and findings shall be properly documented and followed up. Accommodation, catering services areas and work site shall maintain acceptable standard of hygiene and good house keeping GENERAL SECURITY PLAN The project team led by the ERSU Manager shall ensure that adequate security arrangements are made to handle security related incidents effectively. The project team will identify, evaluate and manage risks to personnel and property arising from theft, malicious practices, crime, civil disorder or armed conflict. In addition, each Contractor will be required to prepare a project security plan and submit to PHCN for review and approval before mobilization to site. The project will also organize a security workshop to identify, evaluate and recommend contingency plans for all security risks Journey Management Plan PHCN and Contractor shall follow its journey management procedures strictly. Trips shall be planned and combined to reduce driving exposures, mandatory use of seat belts by drivers and passengers in company and Contractors vehicles shall be enforced. All drivers shall attend defensive driving course while night driving (out of town limits) shall be discouraged. Each trip/journey to be undertaken during the proposed project shall be managed in such a manner that will not result to harm to life or property. A journey management plan specific to each trip shall be produced and submitted to the Site HSE Coordinator for approval. The details of the journey management plan shall include proposed mobilization date, mode of transportation, routes, type of cargo as well as the details of the JHA conducted for the trip. The Site HSE Coordinator may only approve the trip if he can confirm that all necessary precautions have been taken to forestall transport accidents/incidents. 34

35 10.2 Accident/Incident Management Plan Accidents do not just happen but are caused mainly due to human factors. They result in pains to the victims and their families, and waste of money and resources and time to the Company. Consequently, the main priority to PHCN shall be to prevent accidents during mobilization, construction and operations stages of the proposed projects. Prevention of workplace accidents during the proposed projects shall be achieved using the JHA tool and approved work plan/instructions by supervisors. Consequently, the technical team must conduct JHA for all HSE critical activities and develop written and explicit work plans/instructions for such operations. The work instructions shall integrate the recommendations of the JHA. It is only upon submission of the written work instructions and the supporting JHA document that the Site HSE Coordinator may consider the project activity for approval. Project activities may only be approved if the site HSE Coordinator is objectively convinced that the Written Work Instruction (WWI) are practicable, safe and in accordance with regulatory requirements. The use of JHA and WWI as work management systems shall include job planning and permitting, shift / tour handover meetings and logs, special procedures governing higher risk activities, control of simultaneous activities, energy isolation and workplace preparation, management controls for temporarily removing safety devices, and reinstating the facilities and preparing to restart operations. It shall also include requirements for reviewing completed jobs and capturing and communicating lessons learned about the work and management system. Accidents shall be reported and investigated to the ERSU Manager in line with PHCN accident reporting procedure. All personnel shall be encouraged to report all accidents/incidents and to cooperate in the investigation of such occurrence. Staff shall be made to know that accidents/incidents investigation are fact finding and not fault finding exercises and are particularly useful as lessons in preventing re-occurrence Emergency Response Plan The PMT and Contractors will demonstrate that all potentially significant hazards and potential impacts of the project activities have been identified, the associated risks evaluated and understood, and that control and recovery measures to effectively manage these risks and impacts are in place before mobilization to site. PHCN will assist Contractors, where necessary, with the provision of a generic hazard list for guidance. 35

36 In case of an emergency, Contractor emergency response procedure will be activated. Its objectives are: To ensure no loss of life To ensure that the environment is protected To ensure that manpower, equipment and funds are available to effectively contain the emergency (fire, explosion, electrocution, shocks, accident, spill clean up for oil/chemical, etc) In order to ensure that good record keeping is maintained and accurate information concerning emergency are disseminated to the workers, public and government, the under mentioned procedures cover the information and issues on the following: Transformer shut down Search for leakages Isolation of supply points Notification of authorities Safety precaution and environmental proceedings Repair methods and procedures Emergency repairs Contractor arrangement Re-commissioning and start up The PMT and Contractors will identify all potential emergency situations and develop procedures to use in such scenarios as explosions or fires, hydrocarbon/chemical spills, weather related disasters, hostage taking, community disturbance, kidnapping, etc. Emergency drills will be conducted to demonstrate preparedness for response and schedule of drills and testing of emergency instruments will be prepared by PHCN/Contractors on the proposed projects. Every technical Contractor on the proposed projects will prepare and submit for approval contingency plan for emergency situations and possible incidents beyond the capability of site facilities Consultation Plan This involves soliciting peoples views on proposed actions and engaging them in dialogue. It is characterized by two way information flow, from project authorities to people, and from people to project authorities. The overall aim of the consultation plan for the project therefore is addressing the concerns and opinions of the stakeholders with the ultimate view to assuring a smooth project implementation. 36

37 Consultation about these rehab/reinforcement projects have been initiated by the PMU- ERSU to Federal Ministry of Environment, the World Bank Safeguard Team, PHCN- TCN HQ & project sites, surrounding Communities and shall remain a continuous process during implementation. The programme for the project construction and operations stages include: Visits and courtesy calls on community leaders and other stakeholders to discuss the effectiveness of the addressed social issues on the lives of the host communities. Direct visit to the affected populations to consider (through questionnaires, interviews and visual observations. Organizing large public meetings (participatory rural appraisal- PRA) to discuss public welfare, clarify misconceptions and address new issues as regards the project. Holding workshops and extension courses on resource management (using simply written materials, visual representation, videos and scale models to decode technical languages) and sensitising local people on the latest impact mitigation techniques. Organizing public seminars aimed at identifying new ways of rendering socio-economic assistance for the locals. Establishing a voluntary participatory programme in the local media, television and radio) through which NGOs, CBOs and other key stakeholders concerned and the general public can comment on various aspects of the project and to ensure that all socio-economic and environmental issues are adequately addressed. In case of any Grievances, the affected person(s) should come to or write the CEO of PHCN-TCN and copy the head of Substation who then will attempt to resolve any grievance. He will liaise with the PMT in sorting out the grievance and notify the CEO PHCN. When the CEO of PHCN-TCN cannot resolve the grievance himself, the offended can then seek redress from any Court of Law in Nigeria Communication Plan Effective two-way communication between PHCN and Contractor staff on HSE and security issues will include awareness programmes to motivate staff and Contractors. HSE and security information experiences will be shared between PHCN and Contractors to facilitate improvement in HSE and security performance. Contractor shall ensure its staff involved at all levels in the proposed projects become familiar with the importance of compliance with the adopted HSE policy, regulatory 37

38 compliance plan, security plan and their individual roles and responsibilities in achieving their compliance. Each person shall be aware of his respective work activities, inherent job risks and hazard and their controls, mitigation measures and emergency and response procedures that have been established. They also need to be aware of potential consequences of departure from agreed operating procedures. Consequently each Contractors will have a project communications focal point to enhance communications with the Contractor project team at various locations. Contractors will set up appropriate procedures and lines of communication to handle HSE and security issues (e.g. direct access to the nearest clinic, direct access to emergency services, etc). Contractors should be able to communicate easily with their base offices, work site and local PHCN in an emergency situation. Appropriate safety programmes and promotions need to be employed in order to effectively promote HSE and create awareness e.g. minutes of meetings, plans and performance targets, HSE performance on news board, posters, bulletins, video, news flash, etc. Appropriate HSE incentive programmes should be established to promote individual HSE performance improvements e.g. suggestion boxes, personal recognition, observation of annual safety week, HSE performance bonus schemes etc COMMISSIONING/HAND OVER PLAN The risks associated with the commissioning and handover phase of the Projects will be adequately evaluated and will be covered by detailed commissioning procedures and guidelines. The Engineering, Procurement, Installation and Commissioning (EPIC) contract strategy will allow time for familiarity of the commissioning/operation team. This will allow for effective supervision and carryover of priority items into the operation phase. A pre-commissioning audit will be carried by the PMT for the proposed projects. Specific commissioning plans covering all significant Contractor commissioning activities, particularly control of potential dangerous operations during the commissioning will be developed. The proposed facility will not be put into operation unless commissioning approval is received from PMU and PHCN-TCN. 38

39 12.0 DECOMMISSIONING / ABANDONMENT PLAN The design and facilities shall take due recognition of the need to decommission the Transmission Substation and the ancillary facilities at the end of their operational life, the abandonment plan shall take due note of the current national and international legislative requirements. The following shall be consider at the end of the project lifecycle: Need for facilities decommissioning and notification to FMENV. Team shall be set up to study and plan the decommissioning/abandonment programme in a manner that meets standard requirement. An Environmental Evaluation Report (EER) to determine if the activities carried out at the site have caused any detrimental effects and if any, discuss mitigations and restoration measures. In-depth Environmental Studies for the actual removal of equipment (demolition) has to be carried out. BRIN KEBBI SUBSTATION PHOTO SHOTS Plate 1 39

40 ABANDOUNED NON FUNCTIONNING TRANSFORMER Plates 2 DRAINAGE PROBLEM/LOW LIFT OF GRAVEL Plates 3 40

41 SCRAPS ALL AROUND THE SUBSTATION 41

42 DEBRIS/SCRAPS LITERED THE AREA (HOUSE KEEPING AND WASTE MANAGEMENT) NEED SCRAPING POLICY (TCN) Plates 4 42

43 PLATE 5 COMMUNITY THAT MAY BE AFFECTED BY THE RELOCATION OF THE OLD 33KV SWITCH YARD (SOCIAL PROBLEM) Plates 6 43

44 POOR GRAVELLING IN THE SWITCH YARD 44

45 Plate 7 OIL SPILAGE FROM A CIRCUIT BREAKER (HOUSE KEEPING, PROPER HANDLING OF TRANSMITTION OIL, PCB BECAUSE OF AGE OF TRANSFORMER) Plates 8 45

46 OIL SPILLAGE (HOUSE KEEPING, PROPER HANDLING OF TRANSFORMER OIL, PCB BECAUSE OF AGE OF TRANSFORMER) Plate 9 OIL STAINS COVERED WITH FRESH GRAVEL AROUND THE 90MVA TRANSFORMER FEEDING NIAMEY 46

47 Plate 10 MAINTAINANCE WORKSHOP SORRUNDING IN SUBSTATION Plate 11 OVER FLOWN DRAINAGE FACILITY IN THE 133KV SWITCH YARD 47

48 Plate 12 NON FUNCTIONAL OIL LEAKING REACTOR Plates 13 48

49 LEAKING TRANSFORMERS Plate 14 49

50 CHOCKED UP CONTROL ROOM 50

51 PLATE 14 Plate 15 SCRAPS AROUND THE STORE HOUSE 51