The sponsor has presented plans to address these impacts to ensure that the proposed project will, upon implementation of the specific measures agreed, comply with applicable host country laws and regulations and World Bank/IFC requirements. The information about how these potential impacts will be addressed by the sponsor/project is summarized in the paragraphs that follow.
IFC required completion of an independent environmental review of this project (including the existing and new terminals pipeline, jetty installation, and railroad links). The sponsor has confirmed that no shipping operations form part of the project/Gapco (Kenya) Ltd and that Gapco (Kenya) Ltd. responsibility is only from the unloading point. This review includes development of an corporate Environmental Health and Safety (EHS) Policy and Waste Oil and Liquid Effluent Control measures. The independent review of the new installation has been completed and the review of existing operations is currently ongoing, receipt of the independent report for existing operations will be a condition of first disbursement.
Land Use/Site Location
The existing Gapco site is on Kenya Ports Authority (KPA) land and the new site is located on the KPA boundary. The sponsor has confirmed that no physical/economic displacement of people/commerce/land use is associated with the project. The new site is bounded by existing petroleum installations, a railroad, KPA flats, and the Kipevu Creek (which is connected to the port). As established by the independent study, the KPA flats are, based on American Petroleum Institute (API) and U.K Institute of Petroleum (IP) requirements for a Class 3 facility, sufficient distance (i.e., one half of tank diameter or a minimum 15 feet) from the storage tanks. Key environmental and safety issues are therefore limited to industrial hazards management (emergency response, spills contingency, fire/explosion, safety, training, housekeeping, monitoring and equipment requirements for all phases and operations) and waste/fugitive oil management. The project involves virtually no waste production except for domestic waste as it is only a blending and redistribution facility.
Water and Power Supply
The terminal will be supplied with water from the municipal mains . The day to day usage of water by the terminal is limited to the office/toilets and terminal house-keeping, this demand can be met without any adverse impact on other users. The requirements of power for the terminal , mainly for pumps, compressor, mixers for fuel blending and night security lighting have been assessed by the power company and they confirm that they will meet the demand. An appropriately sized standby generator will be installed to provide operational and emergency back-up, this will be equipped with secondary containment. There will be no requirement for steam at the Terminal . Fuel oil/gasoil blending will be done using mechanical mixers and compressed air.
Waste Management (Effluent, Oil and Stormwater)
No process solid waste will be generated as part of the project. The key waste is domestic sewage and solids, waste oil and stormwater. All domestic waste (including sewage and solids) will be handled by the KPA and the municipal authorities, these amounts are small and can be handled by the authorities in compliance with local requirements.
With respect to oil and stormwater the plant design to API standards ensures that spills containment is controlled and separated from water drains and that seepage into the ground is minimized/eliminated ( bundwalls, interceptors etc ). A comprehensive operating procedure will be put in place to ensure that spills are minimized and if accidental spills do occur there will be an effective emergency response plan to reduce the adverse impacts.
Waste oil, gasoil and fuel oil, can emanate from any one of the following sources in the normal plant operations.
· Accidental and operational product spills in the terminal.
· Sludge from tank cleaning.
·Sludge from water/oil separators cleaning.
The plant will be equipped with three API standard water/oil separators to collect spills and waste oils from the key operating zones i.e. tankfarm, railcar loading, truck loading, pump house. The interceptor outlets enter the main storm water drain leading to the Kipevu Creek.
A procedure will be implemented to manage collection, storage and disposal of waste oils collected from the water/oil separators or any oil scooped from a spill outside the drain system. The procedure will entail:
· Collection in drums, clear labeling of the source, date and storage in a designated area;
· An arrangement will be made with one of the steel or cement factories for incineration of the sludge/waste which will be delivered in the drums (temperatures of the kilns will be minimum 1000 deg C);
· Recordkeeping of waste oil disposal; and
· Periodic verification that incineration is to standard and minimum temperature.
A procedure will be put in place on the sampling and testing of effluent from the interceptor outlets and also from the final point of stormwater exit into the creek , this will cover the following:
· Engage an environmental laboratory to independently sample and test the effluent at the designated outlets every three months;
· Compare test results with the applicable limits ( Kenya and IFC/World Bank);
· Take corrective actions to clean the interceptor;
· Maintain the records of the tests and corrective actions taken; and
· Always maintain a visual surveillance of the creek to ensure that no unsuspected oil is draining or seeping into the creek, especially after heavy rainstorms.
HAZOP (Hazards Assessment)
With respect to safety, training, emergency response, and equipment needs an independent HAZOP is necessary and will be completed for all operations (including the tank farms, pipeline, and jetty installations) by an independent specialist. Given that design plans for the new facility have not been finalized yet HAZOP completion is not possible at this stage, consequently HAZOP submission and review by IFC will also be a condition of first disbursement. All of the issues summarized below will form the key elements off the HAZOP study.
It should be noted that Gapco intend to ensure project compliance with international best practice standards. The existing condensate installation and was purchased from a major oil company and expanded and refurbished to include state of the art fire and safety protection equipment consistent with NFPA standards (including floating roofs, foam injectors, and cooling waters). The new facility is being built to meet American Petroleum Institute (API) and U.K. Institute of Petroleum (IP) standards and will also include state of the fire protection equipment compliant with NFPA requirements. The plant will have a fire water system including a 1500 m3 fire water tank and foam storage , ring main fire hydrant with fire monitors and foam mixers , all supported by two diesel pumps and two electrical jockey pumps. Key safety procedures/elements will include:
· Sound safety and operating procedures including fire drills will be developed to ensure risks of plant fires are minimized;
· Regular plant and equipment inspections plus a preventive maintenance program will reduce exposure to fire incidents;
· The terminal emergency response plan will detail an evacuation plan for the residents in the adjacent KPA flats in case of a fire;
· High Level Alarms to warn against tank over-fills during marine receipts;
· Construction of a bundwall around the tank-farm and a concrete pavement on the floor of the tank-farm to contain any spill within the bundwall; and
· Provision of suitably designed water/oil separators at the truck and rail loading areas, and for the tankfarm to contain any spilled oil before entering the storm water drain.
Operating and EHS Procedures are being developed as a part of the independent review to cover all aspects of the terminal operation, including:
· Contractor work control procedures;
· Personnel safety and health program;
· Tank product receipts procedures;
· Truck and rail product loading procedures;
· Preventive maintenance program;
· Effluent control procedures; and
· Security and access control procedures.
Development of the following procedures:
· Tanker to shore product discharge procedures (in coordination with KPA)
· Interceptor operating procedures;
· Tanks water drain procedures;
· Bundwall drainage procedures;
· Truck and railcar loading procedures (in coordination with KPA and Kenya Railways);
· Housekeeping procedures; and
· Sound plant and truck inspection and preventive maintenance procedures.
The Terminal will ensure that the occupational health and safety guidelines are practiced.
· Training will be given on various hazards and accident prevention;
· Training will be given on the Materials Safety Data Sheets for the two key products being handled at the terminal;
· Personal Protective Equipment ( Helmets, gloves, masks, safety shoes, overalls ) will be provided and their use always practiced;
· Training will be given on emergency response and use of various emergency equipment in the plant;
· Exposure limit levels at the loading areas will be measured and records maintained;
· Regular medical checks ( every two years ) will be done on employees in critical operations e.g. loading operations; and
· Records of all incidents ( spills, fires, injuries, occupational illnesses ) will be kept for performance monitoring.
An EHS Policy has been prepared and an EHS Committee to steward EHS performance and monitoring will be composed of the following: Terminal Manager ( Chairman ) , EHS/Maintenance Supervisor ( secretary ), Operations supervisors, Shipping Supervisor, and a Security Officer.
The following summarizes the action items required to mitigate the potential risks at the Gapco Terminal in Mombasa and to ensure that an effective ( EHS ) program is in place.
Terminal Design Features
· The installation of level control systems including high level alarms.
· Provision of a pavement floor for the bunded tank farm area.
· A channel at the main gate to divert storm run-off water from entering the terminal.
· The tanks facing the KPA flats should be painted in "matt" to reduce glare.
· Setting an effective terminal organization.
· Establishing operational and EHS procedures and training.
· Establishing an effective EHS Committee and EHS performance monitoring process (to include safety incidents, effluent monitoring, occupational health monitoring).
Emergency Response Plan
- Ensure GAPCO is included in the Shimanzi MUTUAL AID GROUP.
- Acquire the basic emergency preparedness equipment as determined by the HAZOP.
- Discuss with KPA a contingent evacuation plan for the KPA flat residents in case of a major emergency.
Mangrove Replanting
At the time of new site preparation Gapco had filled an area of 3-4 acres to expand the project site. This fill area is bordered by a small area (<10 acres) of mangroves (extremely sparse on the southern end and fairly dense on the northern side). In discussion with IFC, Gapco has agreed to offset any negative impacts that filling/sedimentation would have had on these mangroves (though they appear healthy and intact 3 years on) during filling by replanting mangroves in another location. The area and location to be replanted will be determined by Gapco in coordination with IFC and a local women’s NGO who have an existing mangrove replanting scheme. It is very likely that the NGO will conduct the replanting with direct support from Gapco. Costs associated with replanting are anticipated to be minimal and will cover more than the area potentially disturbed (a minimum double replanting). In addition Gapco has committed that any future expansion/construction will not result in any disturbance or removal of mangroves.
This ERS will be made available at the KPA Headquarters, Mombasa, and at the project site. Availability of the ERS at these locations will be advertised in a major local newspaper.
