Case study 10.4 Thai National Fertilizer Corporation Project
Source ESCAP: Environment and Development Series, Environmental
Impact Assessment, Guidelines for Transport, p. 65.
Notes: This case study can also be used by trainees to develop
mitigation plans and post-project monitoring.
Name of project: National Fertilizer Corporation, Eastern
Seaboard, Thailand.
Type of environmental analysis: EIS.
Type of project: This project is an ammonia and phosphate
fertilizer manufacturing complex. The complex will produce nitrogen-phosphorus
(NP) granules, nitrogen-phosphorus-potassium (NPK) granules, urea granules with
small amounts of ammonia phosphoric acid, mono-ammonium phosphate (MAP), and
di-ammonium phosphate (DAP).
The NFC fertilizer complex will occupy an area of approximately
1.6 km2 on the Gulf of Thailand, and will require an additional area
of more than 1 km2, to the east of the main plant location, for
phosphogypsum storage. The complex will employ a workforce of approximately
3,000 workers during the construction stage, and approximately 700 during
operation.
The complex will produce for sale a total of 670,000 tons per year
of NP and NPK granules; 140,000 tons per year of urea granules; and smaller
amounts of ammonia phosphoric acid, MAP, and DAP. Most of the complex output
will be shipped to domestic dealers for further distribution. This quantity of
fertilizer product represents a sizeable percentage of Thailand's fertilizer
needs.
The complex was scheduled to begin operation in late 1987, based
on the initiation of construction in early 1985.
Solid raw materials required by the complex, with the exception of
filler, will be brought to the complex by ship. Products will be distributed by
barge and by truck, and/or by rail. Water will be supplied from Dok Krai
Reservoir, which has ample capacity to satisfy project needs. Power will be
available from the new facilities of the Provincial Electricity Authority (PEA)
and Electricity Generating Authority of Thailand (EGAT) which are being
developed to serve the growing needs of the Eastern Seaboard Area. These and
other requirements of the complex, such as transportation, port facilities, and
housing for workers, have been included as part of the overall development plan
for the Map Ta Pud Industrial Estate.
The processes and operations that will be used at the complex are
similar to those that are presently in use at many other fertilizer plants
worldwide. No new or experimental technology is utilized in the complex. The
complex is planned to be a modern, environmentally sound facility that benefits
from worldwide experience.
Project location
The National Fertilizer Corporation will be located on the Gulf of
Thailand at the Map Ta Phut Industrial Estate in Rayong Province.
Reports on pertinent studies
See References 1 and 4, pages 316 and 317.
Environmental study area
The study area described by the EIS will include an area within a
20 km radius from the project site. Because most of the impacts caused by
construction and operation of the complex will occur in the project area, this
will be the only area described in depth.
EIA team
The EIS has been basically prepared for MFC by its consultants,
namely TESCO (a Thai environmental consultant), Foster Wheeler International
Corporation, the project management consultant (PMC), and Synco (an
environmental consultant). This was a one-year study involving approximately 30
professionals with specialist inputs on physical resources, ecological
resources, human use values, quality-of-life values, and project management.
EIA budget adequacy
Before the EIA process is started, one needs to ensure that
adequate budget is available to collect data, analyse data available, carry out
necessary research investigations, and develop any appropriate models.
Methodology
The EIS document has been prepared in accordance with information
included in the manual of NEB Guidelines for preparation of environmental impact
evaluations as well as the specific guidelines contained in the terms of
reference (TORs) developed by NEB for the EIS on the particular project. Work in
preparing the EIS has considered all studies and potential impacts identified in
TORs.
The methodology for making an EIS is essentially that prepared by
the Battelle Institute/United States Army Corps of Engineers for water resources
development projects. Here the environmental impacts are studied in four
categories: (a) physical resources, (b) ecological resources, (c) human use
values, and (d) quality-of-life values.
Field studies were performed on each of these topics, and existing
data were used as appropriate.
Existing environmental conditions
Background
At present, the part of Rayong Province where the complex will be
located is largely rural. Cassava cultivation dominates the area, with
sugarcane, fruit trees, pineapples, coconuts, and rice also occurring
frequently. Rubber is also increasing as a local crop. In the immediate vicinity
of the site are several small villages, including Ban Ao Pradu, Ban Nong Faeb,
Ban Nong Ta Tik, and Ban Ta Kuon. At a distance of about 5 km is the
municipality of Map Ta Phut, which has a population of about 7,000. More
sizeable nearby population centres include Rayong, which is about 15 km to the
east, and Sattahip, which is about twice as far to the west.
Cassava processing dominates the industry of the area, with
cassava pellet and cassava flour manufacturing plants the most prevalent
industry by far. There are nine such plants within only a few kilometers of the
plant site. A second significant industry is pineapple canning. However, the
first stages of the planned industrialization of the area are already evident,
namely construction of the PTT Gas Separation Plant. Also, a plastic granules
facility has been built a few kilometers to the east of the plant site, in
Rayong.
Since the plant site is a seacoast area, two activities usually
associated with the ocean are also found, namely fishing and recreation. A small
resort, Haad Sai Thong, is located at Ban Ta Kuon, about 3 km east of the plant
site and 1 km south of the gypsum stack area. The resort is located near the
mouth of Khlong Huai Yai, which is a stream located to the west of the gypsum
stack. Some recreational house plots belonging to individuals are also found in
the area.
The fishing industry is less significant to the area than
agriculture, and fishing activity centres around the mouth of Khlong Huai Yai.
The area is not considered a prime fishery area.
Topographically, the project area is relatively flat. The plant
site is at an elevation of 5 to 10 m MSL. The land rises gradually towards the
inland areas, with isolated hills at distances of 10 km or more from the plant
site. Drainage is good, flowing primarily southward to the sea. Flooding is not
a significant problem.
The area is not seismically active and is far from existing
centres of seismic activity.
Several different types of soils are found in the area, and these
are identified on a soils map presented in the report. In general, the soils
tend to be sandy, well-drained, and low in nutrients.
Although agriculture is important in the study area, the methods
used are not entirely efficient or modern. Fertilizer is applied to crops in
many cases, but in amounts that are generally less than recommended. Therefore,
especially in cassava areas, nutrients in the soil are gradually being depleted.
Farm machinery is used in some cases, water buffalo and cattle in others. Water
shortages have been found to be a problem, which is being addressed in part by a
government programme to encourage the growing of rubber, which has roots deep
enough to reach groundwater, rather than cassava.
Water and power supply to the project area have been incorporated
in plans for construction of reservoirs and electrical substations to serve the
area. At present, the Dok Krai reservoir provides water for irrigation. It is
planned that this water will be transferred to the industrial estate. However,
by the time this occurs, another reservoir, Nong Pla Lai, will have been
constructed to supply irrigation water. Electrical power substations are now
under construction in the region to increase the availability of power for
industry.
Transportation facilities of many kinds to serve future needs of
the area have been planned by the responsible agencies and authorities. These
facilities are at various stages of early development and include highway and
road networks, a railway line, and an industrial port facility for ocean-going
vessels.
Existing environmental conditions
Air quality in the vicinity of the plant site has been sampled at
two locations, and has been found to be generally well within air quality
standards. Particulates were found to be present at levels of 81 to 92
mg/m3. High levels of total hydrocarbons (1,350 to 2,600
mg/m3) were noted, but since the methane portion of the measurement
was not accounted for, the values cannot be compared to standards.
The two air quality sampling stations were located at Map Ta Phut
and Huai Pong, near centres of population and of industrial development. Thus,
it can be expected that air quality elsewhere in the region is better than at
the two locations studied.
In the immediate vicinity of the plant site, there are several
perennial streams but no rivers. The streams, Khlong Huai Yai and Khlong Nam
Hoo, join and flow to the sea at Ban Ta Kuan/Sai Thong. These streams also
border the gypsum stack location on the east and the west, respectively.
Water samplings to date have found the water quality to be rather
poor and affected by upstream discharges from industry and communities as well
as by salt water intrusion. The water level was very low in both streams, and in
the April sampling, Khlong Nam Hoo was found to be stagnant, due to the
irrigation dam being closed. Turbidity was high, as were total solids and total
suspended solids. COD was high, especially in the upper location on Nam Hoo. The
influence of salt water intrusion could be seen at the lower location on Nam
Hoo, since high levels of total solids, sulphate, and salinity were found.
Sea water quality is found to be affected by contaminants in fresh
water discharges, with near-shore water in a state of eutrophication because of
waste organic matter brought in by the streams.
Sub-surface strata in the project area generally consist of sand
near the surface, sandy clay below, grading into a clay layer with very little
sand at even greater depths. A bedrock of granite underlies the area. The depths
and thicknesses of the individual layers vary spatially, with the region nearest
the shore having the most extensive sand layer. Inland areas, namely the gypsum
stack site, have more extensive clay layers.
Groundwater is high in iron, manganese, and turbidity. Low pH was
also found in some cases.
Existing pollution in the area is caused primarily by the human
population and by the cassava processing industry. Wastewater, consisting both
of sanitary waste from residences and of effluent from tapioca plants,
contributes high loadings of BOD to the local streams. Solid waste, that is
rubbish and garbage, is burned, land-filled, or dumped into the sea.
Existing air emissions from industrial sources consist primarily
of SOx and particulates, and are generated by tapioca plants and
other industries in the area.
In the Rayong Province, public health is generally not good,
because of the combined problems of poor sanitation, lack of potable water,
presence of malarial mosquitoes, and insufficient health care professionals.
Malaria, although declining, is still the most common "notifiable disease'', and
of these diseases, causes the greatest number of deaths.
At present, people living in and around the plant site are aware
that the area will be expropriated for the industrial estate. However, those
living in and around the gypsum stack area are not so aware, although rumours
exist. People living in the study area generally perceive the project as
providing socio-economic benefits, including job opportunities and future
development, although they also believe there will be increased pollution as a
result.
Environmental base map
There is not any specified EBM in the report. However, a location
map shows the waterways, transportation routes, pipelines, etc., in the
vicinity.
Environmental effects from the project
Adverse effects on physical resources
Potential impacts to surface water quality during construction
could arise from dust emissions (from vehicles and disturbance of soil cover),
high suspended solids (from storm water run-off), and sanitary waste (from
construction personnel).
The discharge of wastewater from the fertilizer complex, under
all-flow conditions, will increase the concentration of sea water contaminants
in the area near the discharge point. Sea water within a short distance from the
discharge point will be hazardous to marine life. Under misoperation conditions,
sea water pH will be affected in the initial dilution zone and high
concentrations of fluoride and phosphate will be released into the receiving
water.
The turbidity and some dissolved minerals will be increased in the
groundwater. According to the hydro-geological characteristics of the project
area, the major problem in the gypsum stack area is the potential contamination
of shallow unconfined groundwater by leachate from standing water used in gypsum
disposal.
The topography will be affected temporarily during the
construction phase.
Fluoride and phosphorus pentoxide emissions from the NFC plant
will lead to depositions in the soil surrounding the plant site and gypsum
stack.
Construction and operation activities will generate localized
sources of high noise level. During operation of the NFC complex, road trucks
will be used to transport product and some raw materials. It is estimated that
truck traffic volume will be 20 trucks per hour based on 6 days per week. Noise
level from road trucks ranges from 82 to 92 dBA at a distance of 15 meters. Only
the Haad Sai Thong recreation resort will be significantly affected by these
transportation activities.
Construction activities will create additional emission sources
typically associated with large construction projects. These additional sources
include air emissions from construction vehicles and equipment, fugitive
particulate emission from the disturbance of soil cover, water quality impacts
from surface run-off, and potential impacts from the sanitary waste of
construction workers.
Adverse effects on ecological resources
Construction activities at the phosphogypsum disposal area will
impact fresh water ecology in the two streams since the area is very close to
the streams. There will be an increase in total dissolved solids and turbidity
of the water from erosion and run-off. Sedimentation from erosion and surface
run-off will also affect living conditions such as respiratory processes and
feeding habits of benthic organisms and some fishes. The dominant benthic
organism in Khlong Huai Yai was Chironomus sp., which will be affected by
sedimentation.
High concentrations of some chemicals in the NFC plant wastewater
will be a hazard to marine organisms within 3-5 m from the discharge point along
the plume trajectory. Any possible adverse impact from the fluoride will be
limited to a 5 m radius around the diffuser and then it will only affect very
sensitive species (Perna Perna).
Adverse effects on human use values
The NFC will change the existing land use pattern in the project
area from agricultural areas, villages, etc., to the fertilizer plant and gypsum
stack. Houses and the crops in the plant site will be removed and the land
owners will have to find a new place for settlement.
Two unpaved roads located in the plant site area and used by local
commuters will be eliminated by plant construction. Traffic volumes will
generally increase near the project area.
Fluoride emissions from the operation of the NFC plant will cause
some localized impacts on existing agricultural vegetation. An area of
approximately 140 ha, generally north of the gypsum stack, is exposed to annual
average fluoride concentrations above 0.25 μm/m3. Plants
sensitive to fluoride may be affected in this area. Thus the unknown
susceptibility of the majority of crops (cassava, coconut, paddy rice, and
rubber) needs a threshold examination.
Examination of the monthly ground level fluoride air
concentrations reveals areas that receive a two-month average above 0.33
μg/m3. Forage materiais are subject to fluoride accumulation and
if it exceeds 40 ppm (less than 0.33 μg/m3), cattle may suffer
fluorosis. But the areas of potential forage contamination are not in the
pasture, and constitute a maximum of 1.4 per cent of the study area. However,
there is an increased percentage of susceptibility.
Contamination of the streams with increased phosphates and ammonia
will increase the aquatic plant biomass. This will change the ecosystem and thus
affect fisheries.
A small number of swimming crab fishermen may have to move from
the fishing ground adjacent to the project site to fish in other areas. Some
adverse effect of the discharge (fluoride and phosphate) on the larval stage of
fishes and invertebrates may be expected.
Construction of the NFC complex will require resettlement of
villagers who are presently living on portions of land to be devoted to the
project.
Some impact is anticipated at the black sand beach mine at Nong
Baeb. It will depend upon conflict resolution between the mining company and the
government during expropriation for the Map Ta Pud Heavy Industrial Estate
project development.
Adverse effects on quality-of-life values
Impacts will occur from plant construction and operation due to
the number of workers moving into the area. Plant operation will create an area
around the gypsum stack having impacts from fluoride emissions. The majority of
the villagers are aware of possible water and air pollution. During certain
operations, ambient concentrations of contaminants can be expected to increase.
An ammonia spill would have a significant impact on public health.
Measures for offsetting adverse effects
The mitigating measures of the project plan that will offset the
potential impacts are described as follows.
(a) Siting of the complex in an area where many of the existing
environmental resources/values are not of prime importance. The project site:
(1) does not contain any valuable ecological resources (either terrestrial or
aquatic), (2) does not contain any items of archaeological significance or
historical importance, (3) is not subject to floods or seismic disturbances, (4)
is not heavily populated, (5) is not the location of significant mineral
resources or mining activities, and (6) is not a prime area for tourism,
recreation, or aesthetic pursuits. The project will also not compete with local
industry for raw materials, or workers with similar skills.
(b) Procedures in the construction period will involve:
preferential use of local labour to minimize the number of workers who migrate
to the area; establishment of construction camps by subcontractors for migrant
workers; use of dust suppressant spraying to minimize fugitive dust during
construction activities; use of temporary dams to control erosion and promote
settling of particles from stormwater run-off to prevent damage to surface
waters (fresh and nearshore) and aquatic ecosystems; provision of sanitary waste
facilities for workers; and cooperation with local and provincial public health
authorities.
(c) Use of air emission control equipment that limits emissions of
pollutants, including SOx, NOx, hydrocarbons, acid, mist,
ammonia, carbon monoxide, and volatile organic compounds, to levels that result
in ambient concentrations well below applicable air quality standards. Emissions
from the plant will also not create any harmful synergistic effects with each
other (i.e., ammonia with CO) or with other existing emission sources in the
area. Deposition rates are low enough that they will not adversely affect soils.
(d) Siting of the gypsum stack area over a thick layer of
naturally occurring, low permeability clay to serve as a liner that will prevent
seepage of cooling pond water from reaching groundwater or surface water.
(e) Constructing very low permeability dikes around the gypsum
stack down to the underlying clay layer to provide safe lateral containment for
the gypsum pond water and to restrict the potential impact on neighbouring
groundwater to insignificant levels. Analyses show that conservatively projected
seepage rates are so slow that the time required for contaminants to escape the
gypsum stack area exceeds the life of the plant by more than a factor of four.
Use of on-site wastewater treatment to treat effluent from the
complex, followed by use of a well-designed, submerged diffuser 2,000 m from
shore to discharge the effluent to the ocean at a depth of 4 m. Analysis shows
that the sea water quality beyond about 10 m from the discharge point will be
only minimally altered and that no significant impacts will occur on marine
ecosystems or fisheries.
(g) Plant operational procedures that utilize evaporation from the
gypsum cooling pond to minimize wastewater discharge from this source,
restricting it only to part of the rainy season (about 3 months per year).
(h) Stacking of phosphogypsum in the gypsum stack area using
well-established techniques that involve double-diking to minimize the chance of
leakage or spillage of slurry water from this area.
(i) Application of noise criteria that will meet United States
Occupational Safety and Hygiene Association (OSHA) standards for occupational
noise within the plant boundary. Any equipment not meeting noise control
standards will be subject to attenuation, and ear protection equipment will be
provided if necessary. Attenuation of plant noise by distance beyond the
boundary will reduce noise impacts on human receptors in the area to
insignificant levels.
(j) Commitment by the project to conduct environmental monitoring
activities during construction and operation of the complex so as to verify the
protection of the health and welfare of workers, nearby population, and the
surrounding environment. Monitoring activities will be performed at locations
both within the complex and around it. Significant sources of emissions and
effluents have been identified and will be monitored. The monitoring programme
will cover: (a) sources within the plant, (b) air quality and meteorology, (c)
surface water quality, (d) sea water quality, and (e) groundwater quality.
Selected ecological studies may also be made. The early results obtained will be
used to modify details of the monitoring programme as necessary. To the extent
desirable, the monitoring programme will use the same sampling stations and
parameter lists as in the baseline programme. The monitoring results will be
compiled and reported periodically to the appropriate authorities.
(k) Commitment by the project to perform an occupational health
and safety monitoring programme covering employees of the complex, so that any
concerns can be identified, addressed, and countered by the proper remedial
action.
(l) Project plans to investigate alternative commercial uses for
phosphogypsum to eliminate the need to stack it over the life of the plant.
These commercial uses could include: (a) being a raw material for manufacture of
plasterboard or cement, or (b) application as a soil conditioner (possibly with
lime) to supply calcium and sulphur to soils. These kinds of uses for
phosphogypsum are being demonstrated in Japan and the United States.
In addition to the potential impacts summarized above that are
mitigated by the project design, by regional circumstances, or by the location
of the site, several other potential adverse impacts were identified that will
be mitigated by plans or activities to be developed and undertaken by the
project. The topics involved in these impacts are: (a) fluoride emissions from
the gypsum stack and resulting fluoride impacts on nearby agriculture,
livestock, flora, fauna, and people; (b) relocation of villagers living in the
gypsum stack area; (c) socio-economic and public health issues associated with
low probability "worst case'' emissions or discharges from the complex; and (d)
cooperation with local, provincial, and governmental authorities on
infrastructure and facilities planning so that growth in the area can be
adequately managed.
Environmental monitoring
The project will have an environmental monitoring programme during
both construction and operational phases to provide continuing assurance that
the planned environmental protection measures are working adequately.
During construction, environmental monitoring will be conducted
on: (i) particulate emissions from traffic, earth moving, and debris, and
surface water quality effects associated with construction area run-off at both
the plant site and gypsum stack area. During operation, major sources of air
emissions and wastewater discharge will be monitored at the plant. In addition,
ambient air quality surrounding the plant will be monitored, along with
meteorological conditions. Water quality monitoring will include both surface
and groundwater. Surface water sampling stations on inland streams and in the
ocean will be the same as those used in the baseline study. Groundwater
monitoring will occur both up-gradient and down-gradient from the gypsum stack
in shallow wells. Occupational health and safety of workers at the plant will be
monitored on a continuing basis.
Concluding remarks
The EIS study conducted for the ammonia and phosphate fertilizer
complex was conducted in accordance with the study plan developed with and
approved by the National Environment Board (NEB) of Thailand. The EIS report
produced as a result of the study is compatible with both the NEB's guidelines
for the preparation of the environmental impact evaluation and the terms of
reference prepared by NEB for the NFC project.
Potential environmental impacts associated with constructing and
operating the project were evaluated for a total of 28 separate topic areas in 4
major subject categories (physical resources, ecological resources, human use
values, and quality-of-life values). This evaluation represented a comprehensive
investigation of how the project might affect the environment based on present
plans for its construction and operation.
In the analysis, emphasis was placed on evaluating those impacts
affecting the sensitive receptors that were identified in the project area. Both
routine and non-routine operating conditions for the complex were considered,
including several low probability "worst-case'' conditions. For some topic
areas, no sensitive receptors, issues, or impacts were identified. These areas
received correspondingly less emphasis.
Because of the commitment by NFC to design the plant using modern,
environmentally sound control technology and to take advantage of favourable
existing conditions in locating plant facilities and defining plant operating
procedures, the EIA revealed that many potential impacts had already been
effectively mitigated.
For example, locating the plant in a major new industrial estate
(i.e., at Map Ta Pud) that has been the subject of extensive planning and
analysis by several private and governmental bodies, allows NFC to benefit from
the planned infrastructure development already completed. Utilization of land
for the plant site that is within the territory expropriated by IEAT simplifies
many land use and socio-economic impact questions.
The complex will also benefit from development projects planned in
the Map Ta Pud area for transportation (highways, railway line, and deep-water
port), water supply (from Dok Krai Reservoir), power supply (by PEA and EGAT),
natural gas supply (PTT), and housing (new town - Ban Chang). The effect of this
previous planning is to reduce impacts in these particular topic areas to levels
of no consequence. NFC will coordinate with these other projects to assure their
timely development and compatible schedule.
The overall conclusion is that by using the planned mitigation and
control measures, the NFC project can be constructed and operated without
significant impact on the environment.
REFERENCES
1 Preliminary Report of EIS Study of National Fertilizer Complex,
July 1984.
2 C. Tharnboopha and N. Lulitanon, Ecology of the Inner Gulf of
Thailand, Marine Fisheries Laboratory Technical Paper No. 4/1977 (in Thai).
3 C. Tharnboopha, Water Quality off the East Coast of the Gulf
of Thailand, Marine Fisheries Laboratory Technical Paper No. 10/1979, 1980
(in Thai).
4 Study of Pollution Control Measures and Impacts of the
Development of Chemical Fertilizer Complex and Integrated Steel Industry,
Mahidol University, Volume IV, Environmental Status and Impacts on the
Development of Chemical Fertiliser Complex and Steel Industry on the Sea-Coast
in the Eastern Region of Thailand, 1983.
5 The Directory of Industrial Factories in Changwat Rayong,
Rayong Provincial Industry Office, Ministry of Industry, 1982.
6 S. Khetsamut, et al., Benthic Animals off the East
Coast of the Gulf of Thailand, Marine Fisheries Laboratory Technical Paper
No. 11/1979, Dept. of Fisheries, 1979 (in Thai).
7 Report on Initial Evaluation on Major Industry on the Eastern
Seaboard, Environmental Working Group, National Environment Board, Volume 1,
March 1981.
8 Development Document for Effluent Limitations Guidelines and
New Source Performance Standards for the Basic Fertilizer Manufacturing Point
Source Category, United States EPA, March 1974.
9 Guide to Pollution Control in Fertiliser Plants, United
Nations Industrial Development Organization, Monograph #
9.
