ENVIRONMENTAL AUDIT REPORT OF LARABEE ENTERPRISES LIMITED Plot 62, Phase 3, Sharada Industrial...

Prepra nig ltd October 1, 2014

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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 i

List of Prepares ii

List of figures iii

List of Tables iv

Table of contents v – ix

Acknowledgement x

Exclusive Summery xi - xii

CHAPTER ONE: 1.0 INTRODUCTION

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1.1 Background 1 - 3

1.2 Objectives of the Environment Audit 3 - 4

1.3 Terms of Reference of the EA 4

1.4 The Audit Criteria 5

1.5 Scope of the Audit 6

1.6 Approach and Methods 6

1.6.1 Pre - Audit phase 6 - 8

1.6.2 On site - Phase 8

1.6.2.1Conducting Opening Meeting with Factory Manager and Sites

Personnel

8

1.6.2.2 Undertaking review of relevant documents 8 - 9

1.6.2.3 Conducting Staff Interview to obtain Information on Actual

Practices

9

1.6.2.4 Conducting on Site Inspection with relevant Audit Checklist 9

1.6.2.5 Collecting Sample for Analysis 10

1.6.2.5.1 Procedure for Collection of Water Samples 10

1.6.2.5.2 Evaluation of the quality of waste water 10

1.6.2.5.3 Measurement of Temperature, pH and Conductivity 10 - 11

1.6.2.5.4 Determination of total solids, suspended, Dissolved solids and

Total ash

11

1.6.2.5.5 Conducting Material balance 11 -12

1.6.2.5.6 Debriefing of the management on audit findings,

recommended corrective actions

12 -13

1.6.2.5.7 Environmental Monitoring data 13

1.6.3 Post Audit Activities 13

1.6.3.1 Actions in post Audit phase 13-14

1.6.3.2 Evaluation of Findings 15


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1.6.3.3 Steps after analyzing the findings 15

1.6.3.4. Implementation of the Action plan 15

1.6.4 Audit period 15

CHAPTER TWO: 2.0 OVERVIEW OF LARRABEE ENTERPRISES LTD

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2.1 Company Profile 16

2.2 Location of Larrablee Factory 17 - 18

2.3 The Process Technology 18

2.3.1 Raw Material for the Tanning industry 18 -19

2.3.2 The tanning Process 19

2.3.2.1 Currying 19 -20

2.3.2.2 Beam House operations 20

2.3.2.3 Soaking 20

2.3.2.4 Liming 20 - 21

2.3.2.5 De-liming and Bating 21

2.3.2.6 Pickling 21 - 22

2.3.2.7 Retanning 22 -23

CHAPTER THREE: 3.0 BASELINE ENVIRONMENTAL ASSESSMENT

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3.1 Description of the Surrounding Environment 24

3.2. Existing Environmental management system 24

3.2.1Environmental Policy of Larrabee Enterprises Limited 24 - 26

3.2.2 Implementation of the EMP 26 - 27

3.2.3 Compliance with Environmental laws and regulations in Larrabee 27 - 29

CHAPTER FOUR: 4.0 AUDIT FINDINGS

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4.1 Observation and Evaluation of General housekeeping 30

4.1.1Waste generation from Larrabee 30 – 31

4.1.2 Impact valuation 31

4.1.2.1. Waste Water Disposal 31- 33

4.1.1.2 Solid Water disposal 33- 34

4.1.2.3 Compatibility 34

4.1.2.4 Fuel Dump 34

4.1.2.5 Cloakroom/Conveniences 34

4.1.2.6 Safety signs 35

4.1.2.7 Soil Analysis 35

4.1.2.8 Muster point 35

4.1.2.9 Fire Extinguisher 36


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4.1.2.10 Illumination 36

4.1.2.11Noise level 36

4.1.2. 12 Air Quality 36- 37

4.1.3 Compliance with extant regulations 37

4.1.3.1Compliance with Environmental Regulations 37 - 38

4.2.1.2 Compliance to other regulations 38

4.1.2 Socio- Economic Impact 38-39

CHAPTER FIVE: 5.0 RECOMENDATIONS

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5.1 General Recommendations 40

5.2 Specific Recommendations 41

5.2.1 Elimination of Waste 41

5.2.2 Reuse of waste 41

5.2.3 Recycling of Waste 41

5.2.4 Disposal after compaction, drying or other treatment 42

5.2.5 R Retention /Redirect 42

5.2.6 Separation/concentration 43

5.2.7 Determination of specific water consumption 43

5.2.8 Produce by products from waste generated 43- 44

5.2.9 Reducing Noise level and Gaseous pollutants 44

5.2.10 Compliance to all extant regulations 44

5.2.11 Compliance to all extant regulations 44

CHAPTER SIX: 6.0 FOLLOW UP PLAN

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6.1 Completion and Submission of EA 45

6.1.1 Submission of EA report 45

6.1.2 Monthly effluent monitoring and sending results to NESREA and

Kano state Ministry of Environment

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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

factory identified

45

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

leaking oil/water pipes

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CHAPTER SEVEN: 7.0 CONCLUSION 46


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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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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.


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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 day-

to-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 long-

term 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.

1.3 TERMS OF REFERENCE OF THE EA

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 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


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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.


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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


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potential 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.


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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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1.6.3.2 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.


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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 Plot 62, SHARADA INDUSTRIAL ESTATE,

PHASE 111, Mailing Address 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 Consumables DIESEL,PETROL,LUBRICANTS, GREASE etc

Manpower: Skilled 34

Semi skilled 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


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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


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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:


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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


33

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 re-

tanning. 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 re-

tanning 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:-


34

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.


35

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


36

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


37

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,


38

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


39

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


40

Section 17 of Regulation S.I.9

Factories Act CAP 126 LFN 1990


41

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


42

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.


43

Table 2: Comparison of Larrabee effluent analysis with NESREA standards

Parameter NESREA permissible limits Larrabee Effluent

Analysis Results Temperature Less than 40(0C) 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

methylene

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


44

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


45

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.


46

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 Values measured

Ph 8.0

Temperature(°c) 23.9

Moisture content (%) 1.9

Base saturation (%) 85

Organic matter (%) 1.3

Oil and grease(mg/kg) 0

Total hydro carbon(mg/kg) 0

Nitrate(mg/kg) 63.1

Phosphate(mg/kg) 3.6

Chromium(mg/kg) 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


47

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 Noise level

NEAR THE GENERATOR HOUSE 108dB

AVERAGE WITHIN THE FACTORY 70dB

NEAR THE OFFICES 40dB

NESREA STANDARD FOR INDUSTRY 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.


48

Table 5 :Air quality in the Larrabee factory

Sites within Larrabee CO N02 S02 H2S CH4

Near the generator/effluent

plant

2 3 0.67 1.81 0.11

Near the offices 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


49

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


50

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.


51

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


52

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.


53

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.


54

5.2.6 Separation/concentration

This should involve separating out solid or other materials from wastewater. Low-

technology 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 m3 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 pre-

processed before use in a digester (biomethanation) for energy production. The


55

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


56

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


57

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.


58

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:

…………………………………………………………………………………………………

………………………………………………………………………..


59

1.5 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 How would you rate the conditions of your drains and pipes?

- Good

- Fair

- Poor

2.6 How do you keep the floors of your facility free from spent oil/grease and lubricants?

………………………………………………………………………………………………………

………………………………………………………………………………………………………

………………………………………………


60

3.0 RAW MATERIALS:

Please list raw materials used and indicate quantities used per day.

(a)

List all raw materials including

industrial chemicals

(b)

Average quantities used per day

(Grms./ Kgs).

(c)

Storage conditions

……………………………………….

………………………………………..

……………………………………….

……………………………………….

……………………………………….

……………………………………….

………………………………….

………………………………….

………………………………….

………………………………….

………………………………….

………………………………….

………………………………

………………………………

………………………………

………………………………

………………………………

………………………………

4.0 PRODUCTS:

4.1 Please list your products and indicate quantities produced per day.

………………………………………………………………………………………………………

………………………………………………………………………………………………………

………………………………………………………………………………………………………

………………………………………………………………………………………………………


61

5.0 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

………………………………………………………………………………………………

………………………………………………………………………………………………

………………………………………………………………………………………………


62

………………………………………………………………………………………………

………………………………………………………………………………………………

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)

………………………………………………………………………………………………………

………………………………………………………………………………………………………

………………………………………………………………………………………………….......


63

If No, give reasons.

………………………………………………………………………………………………………

………………………………………………………………………………………………………

………………………………………………………………………………………………….......

6.8 Where do you discharge the treated/untreated water?

- Into general sewers (………………………….... liter/day)

- Into receiving waters (……………………………. 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).

.………………..…………………………………………………………………………


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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 ……………………………….



12.2 Number of fatalities

Year …………………………….. No. of fatalities ……………………………….




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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?

…………………………………………………………………………………………………

…………………………………………………………………………………………………


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…………………………………………………………………………………………………

13.3 Any prosecution or warning notice and when?

…………………………………………………………………………………………………

…………………………………………………………………………………………………

…………………………………………………………………………………………………

ENVIRONMENTAL AUDIT REPORT OF LARABEE ENTERPRISES LIMITED Plot 62, Phase 3, Sharada Industrial...

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Transcript of ENVIRONMENTAL AUDIT REPORT OF LARABEE ENTERPRISES LIMITED Plot 62, Phase 3, Sharada Industrial...