The project company has presented plans to address these issues and impacts to ensure that the proposed project will, upon implementation of the specific agreed measures, comply with the host country laws and regulations and the World Bank/IFC environment and social policies and the environmental, health and safety guidelines. The information about how these potential impacts will be addressed by the project company is summarized in the paragraphs that follow. Further information is provided in the attached documentation.
- Environmental Assessment and Public Consultation:
An initial environmental impact assessment (EIA) report was prepared in January 2004 by an international environmental consulting company (Environmental Resources Management, or ERM) for Senelec for the proposed 60MW IPP Power Plant in accordance with the Senegalese Code of the Environment and the World Bank Operational Policy on Environmental Assessment. Following a series of consultation meetings with Project affected people held by Senelec and ERM in November 2003, and a public meeting in December 2003, the EIA, together with the Public Consultation and Disclosure Plan, Resettlement Framework and Non-Technical Summary EIA, were disclosed by the World Bank in February 2004. The EIA was one of the documents included in the Request for Proposals made by Senelec and provided in February 2004 to the companies bidding for the project.
After international competitive bidding, a consortium of Matelec and MEE (i.e., the project company) was selected by Senelec as preferred bidder in June 2004, and the PPA was signed in February 2005 between the two. Subsequently, the project company retained ERM to prepare a Supplemental EIA based on the project company’s project design specifications (67.5MW), to update the EIA, to continue public consultation, and to obtain necessary environmental permits from the Senegalese Ministry of Environment. The Supplemental EIA (April 2005) is attached as a supporting document to this ERS. The project company is planning to have a follow-up public meeting in April 2005 and is expecting to obtain the Ministry of Environment’s environmental approval of the project in May 2005.
The project company will have a community liaison officer who will manage public consultation activities and community relations throughout the construction phase and during the operational phase.
- Site Selection and Land Acquisition:
According to the EIA, Senelec selected the Kounoune site over the other alternative site (Tobène) due to its proximity to fuel sources and existing transmission lines. The power plant will be built on an area of about 3 hectares, which is part of a larger area of 14 hectares registered in the name of Senelec. Prior to the adjudication of the land to Senelec in September 2004, the 14 hectare area had the status of public land, but was being utilized by 22 persons from the City of Rufisque for grazing and for growing fruit trees. In 2003, Senelec developed a procedure to compensate persons utilizing the 14 hectares as part of the preparation of the Resettlement Framework for Senelec, in accordance with the World Bank policies. Senelec will sell the 3-hectare lot to the project company for the project and will retain 11 hectares for its own use. Compensation to the 22 land users is the responsibility of Senelec. The acquisition of the 14 hectares does not involve physical displacement (the area does not contain dwellings or other structures).
- Buffer Zone Requirement and Possible Relocation of School and Houses:
The 2002 Senegalese Environment Code (the Code) (article L13) mandates a 500 meter buffer zone for all Class I projects (defined as projects with severe environmental impacts). The project has been classified as a Class I project. The Code prohibits dwellings, rivers, lakes and roads within the buffer zone. However, the Code does not specify how the 500 meters should be measured and the regulations for the application of article L13 have not been issued yet. Based on consultation with the Ministry of Environment, the Project Company understands that the 500 meters should be measured from the boundaries of the facilities or equipment that represents risk.
There are several villages within 1 to 2 km from the project site (e.g. Kounoune, Kounoune Ngalap), but the closest is Darou Rahmane, an area recently zoned for urban expansion and that currently has defined lots but few constructed houses, located about 400 to 500 m south of the project site. Darou Rahmane has a primary school of approximately 650 pupils located 500 m from the installations of the project. Assuming that the 500 m buffer zone is counted from the boundaries of the plant’s installations (and not from the boundary of the project company’s property or the boundary of the substation adjacent to the plant but within Senelec’s property), the school is not within the buffer zone. However, the buffer zone includes 34 residential lots (29 vacant lots and 5 with dwellings under construction) and 7 agricultural lots (6 privately owned and 1 considered public land, but being utilized by local people).
Senelec has already announced that it will relocate the school and has defined a buffer zone based on the total area of its property, possibly in anticipation of future projects. Compensation payments and relocation procedures associated with the establishment of the buffer zone will take place according to the standards specified in the Resettlement Framework prepared by Senelec for the World Bank. The local authorities are responsible for preventing the construction of residences or commercial structures within the buffer zone.
- Air Emissions and Air Quality Impact:
The project will use nine sets of Mitsubishi MARK-30B diesel engine (to produce in total 67.5MW) fueled by HFO. The Supplemental EIA explains that the Project’s emissions will comply with both Senegalese air emission standards and the World Bank Group guidelines as summarized in Table 1 (found below as an attachment). The project company will conduct stack emission testing annually to confirm compliance, and use surrogate performance parameters (combustion parameters, sulfur and heavy metal contents in fuel) to continuously monitor compliance status.
Air mitigation measures proposed in the Supplemental EIA include limiting sulfur content of HFO to the extent possible (less than 2.0%), 60 meter stack height (stack height may be adapted if use of very low sulfur content HFO is guaranteed with fuel suppliers and if further refined air quality impact study for both SO2 and NOx has proposed an alternative stack height), locating stacks together to have more flue gas volume for better air dispersion, higher flue gas velocity, etc. Based on these emissions assumptions, maximum ambient air quality impacts are predicted in the Supplemental EIA as in Table 2 (found below as an attachment).
As shown in Table 2, ambient air quality levels around the project site are predicted to exceed the relevant Senegalese ambient air quality standards for a limited number of hours for NO2 (1-hour Max) and days for SO2 (24-hour Max). In order to mitigate the potential impacts from the plant, the project company is planning to undertake continuous air quality monitoring at the location of predicted maximum impact outside the project site and meteorological monitoring at the plant. This data will be analysed and reported monthly to identify any exceedences of Senegalese air quality standards or World Bank Group ambient air quality guidelines. If the monitoring results indicate a significant number of exceedences, the project company will undertake a further study to identify and implement the relevant measures to reduce impacts on air quality from the facility. The project company will also use passive samplers (diffusion tubes) to monitor monthly average ambient air quality levels to supplement the continuous ambient air quality monitoring station. This overall plan would assist in the validation of the air dispersion modeling study in the Supplemental EIA, and provide further information regarding the air quality impacts from the project and the effectiveness of mitigation measures on an ongoing basis.
- Noise:
The diesel engines will be installed within a building with sufficient soundproofing which will significantly reduce noise emissions. The closest residential houses and the school in Darou Rahmane district are about 500m from the project site, and the Supplemental EIA predicts that the noise levels will comply with the World Bank Group noise guidelines for residential and educational receptors. Noise levels will be monitored annually at relevant residential receptors.
- Water Supply and Wastewater:
The project will receive a small quantity of fresh water (less than 2000 litre per day) from Sénégalaise des Eaux. About 200 litre per hour of demineralized water will be produced by an onsite water treatment facility. Residues from the demineralization facility and wastewater from the plant will be treated at an onsite wastewater treatment facility (neutralization, floating skimmer). The wastewater, after treatment, will be used for grass watering and discharged to an evaporation area. The discharge levels are controlled to comply with both Senegalese wastewater discharge standards (NS 05-061, July 2001) and the World Bank Group liquid effluent guidelines.
- Solid and Liquid Waste and Incinerator:
The project will produce solid and liquid wastes such as sludge from HFO treatment (centrifugation), used lubrication oil, hydrocarbon residues collected in the retention area, waste from regeneration of resins, rags, sawdust etc. The project will have an incinerator on site for oil-contaminated wastes, sludge from HFO treatment and other solid wastes. The project company will arrange a way to dispose ash from the incinerator in an environmentally acceptable way. The project company’s first priority is to recycle and reuse wastes to the extent possible, and the incinerator would be used only as the last safety mean to reduce wastes.
- Fuel Storage and Risk Assessment:
HFO delivered to the project site will be stored by 2 tanks of 2,500m3 each. The Supplemental EIA states that HFO storage by the project has a relatively small risk of fire or explosion compared with other lighter fuel oil. The plant will have a flammable vapor detector and a system of controlling ignition. Fuel storage tanks will have a sufficient retention structure to capture accidental leakage. Results of detailed risk assessment and recommended measures by ERM are included in the Supplemental EIA. Under the worst scenario (i.e., accident at the fuel oil storage tanks), the risk assessment recommended that fuel oil storage tanks are located at least more than 200m from the nearest residential areas or public places. The nearest residential district (Darou Rahmane) is about 500m from the project site, meeting this recommended minimum distance. The project company will incorporate the various recommended measures into in the Environmental and Social Action Plan.
- Greenhouse Gas Emissions:
The project is designed to have a higher generating efficiency of 45% (Low Heat Value (LHV) basis) than conventional steam power plants of about 33% (LHV basis). Assuming an annual capacity factor of 80%, the Project is estimated to emit 288,000 ton of CO2 per year at 610 gCO2/kWh performance. This performance is better than the current Senegalese national average of 837 gCO2/kWh for oil-fired power generation (2000-2002 average, Source: International Energy Agency).
- Health and Safety Management and Emergency Response Plan:
The project company will establish an Occupational Health and Safety Management System to ensure that operators, workers and contractors are trained and protected from occupational health and safety risks. An Emergency Response Plan will also be prepared to ensure that adequate responses are properly implemented to minimize consequences on both workers and affected communities in an emergency situation.
- Future Plan for Expansion of Kounoune Power Plant Complex:
The EIA and the Supplemental EIA explain that there may be a future power plant expansion project within the 14-hectare plant site acquired by Senelec. If such an expansion is implemented, the Supplemental EIA analyzes that a major reduction of NO2 and SO2 emissions from the project company would be necessary to ensure that Senegalese air quality standards will continue to be respected. Based on this, the project company was advised by IFC to design the site layout to set aside space for additional flue gas treatment facility (e.g. Selective Catalytic Reduction) if so determined necessary in the future.
- Associated Facilities (Fuel Pipeline and Transmission Line):
HFO will be delivered by a 6.1 km HFO pipeline to be constructed from Cap des Biches to the Project site by the Project Company. The routing will be in parallel with an existing gas pipeline. The project company will construct, maintain and operate the pipeline. Only a short connecting transmission line and a new substation will be constructed by the project company. No major environmental or social impacts are predicted in the Supplemental EIA for these associated facilities.
- Environmental and Social Action Plan (ESAP):
The Supplemental EIA includes a proposed Environmental and Social Action Plan with mitigation measures, management arrangement and monitoring program. Details of the ESAP, once finalized and agreed with IFC, will be disclosed by IFC as an update to this ERS. The project company will assign an environmental, health and safety officer to manage implementation of the ESAP for both construction and operational phases.
- Corporate Social Responsibility Initiative:
The project company is committed to implementing community development activities for the surrounding villages as part of their corporate social responsibility initiative. An assigned community liaison officer of the project company will design and implement these activities.
