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 SO_x 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 SO_x, NO_x, 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.