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Implementation of the UNEP report

The UNEP report was commissioned by and delivered to the Federal Government of Nigeria. Many of the most important UNEP recommendations – such as the creation of an Ogoniland Environmental Restoration Authority and an Environmental Restoration Fund for Ogoniland – are directed at the government and require the government to take the lead to co-ordinate the activities of the many stakeholders involved. Other recommendations concern the Ogoniland community, the oil industry operators and SPDC.

SPDC is taking clear action to address the latter. The Presidential Committee, established to review the report, delivered its recommendations to President Goodluck Jonathan in May, 2012. SPDC welcomes the announcement by the Minister of Petroleum (July 20, 2012) to establish Hydrocarbon Pollution Restoration Project, with a pledge to fully implement the UNEP report and urges the government to take decisive action and leadership to address the serious issues it raised. SPDC is willing to play its part. 

Coordinated action is also required to tackle the large-scale oil theft and illegal refining which continues to have devastating environmental impacts across the Niger Delta. SPDC is advocating more concerted efforts by all stakeholders and hopes that the UNEP report will drive real change in Ogoniland and the wider Niger Delta.

SPDC Actions

While awaiting the government leadership on the overall implementation of the UNEP report, which requires concerted and coordinated action by many parties, SPDC has taken or is involved in a number of related activities in Ogoniland, which address some of the issues UNEP raised until a more comprehensive response begins.

Emergency measures

Although the recommendations for public health are not directed specifically at SPDC, in June 2012, SPDC launched a community health outreach programme – ‘Health in Motion’ – in Ogoniland. Under this initiative, delivered in partnership with RVSG, communities and local governments, medical staff and facilities tour towns and villages across Ogoniland setting up temporary centres and providing primary health care services direct to communities including: eye testing, dental care, blood sugar testing and cancer screening, HIV/AIDS and malarial tests and minor surgeries.

The first outreach took place in the Eleme local government area June 18 -23 and attended to over 4,000 patients across Eleme local government in six outreach centres. A further 4500 children were de-wormed. The Health in Motion programme is planning to visit communities in all four Ogoni local government areas and two adjacent areas between now and the end of August 2012.

In addition to the direct benefits of health care provided, the programme will also generate valuable health data for the RVSG.

  • Is working closely with the Rivers State Government (RVSG) to help fund the delivery by RVSG of 250,000 litres of potable water per day by truck to the most affected communities in Ogale (including Nsisioken), Ebubu and Okrika. SPDC is also partnering with RVSG on a more sustainable permanent water supply project (see below).
  • Has worked with Eleme Local Government to design and produce signs and notices as recommended by UNEP to warn members of the public around impacted locations. The signs have been installed by the local government authorities.

Remediation Management System review

SPDC has completed a comprehensive review of and made changes to its Remediation Management System (RMS) in line with international best practice. The RMS is the main set of SPDC procedures which govern how the company conducts remediation. SPDC will keep its RMS under periodic review and update it as necessary.

In addition to reviewing and updating its RMS, SPDC is also working with two independent international organizations to strengthen and provide further transparency around SPDC’s environmental performance. In March 2012, Bureau Veritas – an independent international standards verification agency – began work reviewing SPDC’s emergency spill response and initial clean up practices. Under a contract signed earlier this year, Bureau Veritas will visit the Niger Delta once every quarter for a number of weeks and – alongside SPDC and representatives of civil society and NGOs – will visit spill sites to verify the work underway.

SPDC has also invited the International Union for the Conservation of Nature (IUCN) – a body comprising amongst others academics and environmental NGOs – to set up an independent scientific panel to advise the company. The panel will provide recommendations to help restore the biodiversity and habitats at spill sites related to SPDC facilities and to recommend possible improvements, where necessary to company standards for remediation and rehabilitation of such sites.

Permanent water provision

SPDC and RVSG have been working to install permanent water facilities (waterworks with water wells, water distribution pipeline network, treatment plant and booster station) in Eleme Local Government Area. When complete, currently expected sometime around September 2012, about 25km of new pipelines are expected to provide running water to residents across Eleme. As at beginning of July, approximately 70% of pipelines had been installed. The work is being executed by local contractors ensuring economic benefits of the project remain in the community.

Health outreach

Although the recommendations for public health are not directed specifically at SPDC, in June 2012, SPDC launched a community health outreach programme – ‘Health in Motion’ – in Ogoniland. Under this initiative, delivered in partnership with RVSG, communities and local governments, medical staff and facilities tour towns and villages across Ogoniland setting up temporary centres and providing primary health care services direct to communities including: eye testing, dental care, blood sugar testing and cancer screening, HIV/AIDS and malarial tests and minor surgeries.

The first outreach took place in the Eleme local government area June 18 -23 and attended to over 4,000 patients across Eleme local government in six outreach centres. A further 4500 children were de-wormed. The Health in Motion programme is planning to visit communities in all four Ogoni local government areas and two adjacent areas between now and the end of August 2012. In addition to the direct benefits of health care provided, the programme will also generate valuable health data for the RVSG. 

Clean up

SPDC continues to effect clean-up of sites in locations where communities have granted them access. In the last two years (pre and post the UNEP report) SPDC has remediated over 700 impacted sites across the Niger Delta covering over 1500 hectares including legacy sites such as Bomu-11, Bomu-31, Bomu-manifold, Sime, Nokpor, K - Dere, B-dere and Bomu Well 41/50. In Ogoniland clean up and remediation is ongoing at several locations where we have access, including sites such as: B-dere, Yorla Well 10, Akpajo, Bomu well 27/52 and the Ejama Ebubu spill site.

The cooperation of communities to grant permission to access the sites has been and will be key success factors in making progress. As noted by UNEP, all forms of ongoing oil contamination, including activities such as crude theft and illegal refining which are having a devastating impact in Ogoniland and elsewhere, must be brought to an end before widespread clean-up can be effective.

Community engagement

SPDC is meeting with communities in Ogoniland to share its plans and progress on activities and to listen to their concerns and questions. SPDC is holding town hall meetings and talking directly with community leaders, traditional rulers and youth leaders. During such meetings, SPDC highlights issues raised in the UNEP report and seeks community support for its effort to take on some of the actions pending the government response. The occasions also serve to raise awareness about the dangers of stealing and illegal refining of crude oil and the impact that has on the environment and their own health.

Construction of alternate Trans-Niger Pipeline and Loopline

SPDC has agreed with its joint venture partners on the need to construct an alternate pipeline to evacuate production from its land fields to Bonny Terminal. This is expected to facilitate repair, clean–up and remediation works on the existing Trans Niger Pipeline running through Ogoniland – which has become a major target for oil theft and illegal refineries in the area. This new project remains subject to government approval.

SPDC Commitments

In October 2011, SPDC made a number of commitments which address the SPDC-specific recommendations contained in the UNEP report and has made the following progress:

Commitment: SPDC will revisit the sites in Ogoniland investigated by UNEP to determine whether clean up and remediation have been adequate, and take action as required. SPDC will also review a sample of other remediated sites more widely across the Delta to check that adequate remediation has indeed been carried out.

Progress: SPDC contracted Fugro – an international service provider and the same one which UNEP used during the preparation of the Environmental Assessment of Ogoniland – to conduct soil sampling at the 15 sites identified in the report. Sampling took place between November 2011 and February 2012. The results confirmed soil at all 15 sites is in compliance with regulatory limits. SPDC has since contracted professional service providers to assess ground water impacts at each of these sites and will agree any necessary course of remedial action with the regulatory authorities.

Commitment: SPDC will continue its ongoing efforts to ensure effective supervision of contractors and their full compliance with regulatory and contractual requirements.

Progress: SPDC has reviewed its clean up and remediation procedures. It has re-trained contractors and their supervisors on the recently reviewed SPDC RMS. Between April and June 2012 some 200 contractors also underwent the training on Remediation by Enhanced Natural Attenuation (RENA) - which is an internationally recognized technique appropriate for the Niger Delta and which is the principal remediation method that SPDC employs. The training emphasized the need and importance of effective compliance with the SPDC RMS when executing remediation via RENA, for both surface impacted sites and deeper impacts that require excavation of impacted soil.

SPDC has also assigned dedicated clean up and remediation supervisors to a number of large project sites, such as Ejama Ebubu, Soku, SanBarth, and Opobo where clean up and remediation efforts were substantial, to ensure daily and effective supervision and compliance.

Commitment: SPDC has set up a team to review and develop a comprehensive decommissioning programme and asset integrity plan and looks forward to discussing these plans with the relevant Ogoni communities.

Progress: SPDC has conducted a desktop inventory of its assets in Ogoniland. It has also applied to the Department of Petroleum Resources (DPR) for approval of the Terms of Reference of a planned Environmental Evaluation Report (EER) as required by EGASPIN (Part VIII).  Subject to the support of the communities, once approved, a full scale physical verification (Physical Asset Verification - PAV) of the field assets will be carried out to confirm the desk top work already done. This will require support of government and communities to grant access to the sites.

Commitment: SPDC will continue to engage with the relevant government regulators on the Environmental Guidelines and Standards for Petroleum Industry in Nigeria (EGASPIN).

Progress: SPDC has contacted NOSDRA (National Oil Spill Detection and Response Agency) and DPR (Department of Petroleum Resources) on the Environmental Guidelines and Standards for the Petroleum Industry in Nigeria (EGASPIN) to discuss the paradox of remedial intervention and target values being the same and setting site-specific clean up values. These have been reviewed by the regulators in conjunction with oil companies (including SPDC) and SPDC understands that DPR plans to publish an updated version in the near future.