The Company and the Plant operations are materially meeting the requirements of the original investment agreement, and have procedures in place to demonstrate that their activities comply with applicable Ivoirian laws and regulations. Azito Energie has presented plans to address the Project impacts and to ensure that the Project will, upon implementation of the specific agreed measures, comply with the environmental and social requirements - the host country laws and regulations and IFC Performance Standards. Information about how these potential impacts will be addressed by the Company is summarized in the paragraphs that follow and is also provided in the attached documentation.
PS1: Social and Environmental Assessment and Management System
Social and Environmental Assessment
The currently operational Phase I and Phase II installations of the Azito Power Plant were covered by an initial ESIA developed on behalf of the Company in 1998. The 1998 ESIA covered all three Phases proposed for Azito Power Plant as also the Azito-Abobo T-line & substation (associated facility) and included preparation of a Resettlement Action Plan (RAP) to address involuntary resettlement on account of the Azito Power Plant project and the associated T-line, which was prepared by the Government of Republic of CÔte d’ Ivoire (GORCI). Overall configuration of the Azito Power Plant and the proposed Phase III installations has remained consistent. The ESIA undertaken in 1998 was in accordance with the then applicable IFC Guidelines for the Preparation of an Environmental Assessment, The World Bank Environment, Health and Safety Guidelines for Thermal Power Plants (October 23, 1996), Loi Cadre Portant Code de l’ Environment ‘ (CÔte d’ Ivoire Law no 96-766 of October 3, 1996 and Decree 96-894 of November 8, 1996).
The initial permit from ANDE for Azito Power Plant covers all three phases, including Phase III. Since Phase III was not developed as per the original schedule, a fresh ESIA covering Phase III was sought by ANDE. Accordingly, in 2010, Azito Energie commissioned ERM to carry out an ESIA specific to the Project and in accordance with: the Terms of Reference approved by ANDE; IFC Performance Standards; and The Equator Principles. The ESIA was completed in March 2012. The ESIA, based on updated baseline data, identifies the environmental and socio-economic impacts of the Project and recommends mitigation measures to minimize negative risks and impacts. The ESMP (part of the ESIA) outlines mitigation and monitoring measures to address impacts during construction and operation phases including those relating to: emissions to air; ambient noise; water consumption and risk of contamination; temporary land take; waste handling and disposal; socio-economic impacts; construction workers and labor accommodation; community health, safety and security; and decommissioning. The ESIA will be submitted to ANDE for review by its committee of experts and for public consultation. The feedback received from ANDE, committee of experts and public consultation will be incorporated and final ESIA prepared. Upon submission of this final ESIA, ANDE will consider the ESIA for approval.
Alternatives related to the site location, fuel supply and the no-development option were presented in the ESIA report in 1998. In case of Phase III, the key alternative analysis involved consideration of various alternatives for the main cooling system. In accordance with the alternative analysis recommendation, air cooled condensers have been opted for in the Project.
Social and Environmental Management System (SEMS)
Azito Power Plant is operated by Azito O&M under a Quality, Health, Safety and Environment (QHSE) and sustainable development policy. The QHSE management system implemented at the Plant currently conforms to ISO 9001, ISO 14001 and OHSAS 18001 standards and was first certified by AFAQ in 2003. The Company has obtained a “maturity” level endorsement under the AFAQ1000NR certification (since 2006) process (social responsibility). Azito O&M as part of its current QHSE management system has in place procedures for: emergency preparedness and response; SEHS training and mock drills; monitoring of health, safety and environmental performance; internal and external audit of HSE performance; reporting to senior management and to external stakeholders on HSE performance; and management review. This QHSE management system will be suitably adapted and implemented to cover Phase III operations as well.
Further, as part of the ESIA, the Company has outlined a management program, including responsibility allocation, to ensure that the Project is constructed and operated in accordance with national requirements and IFC Performance Standards. The Company will contractually require the Project’s engineering, procurement and construction (EPC) contractors to adhere to applicable social and environmental legal/national requirements and fully implement environmental and occupational health and safety (“EHS”) measures defined in Project ESIA. While Azito O&M has in place an appropriate HSE organization, Azito Energie will, for the construction phase, put in place an appropriate HSE organization with roles and responsibilities clearly defined both for the Company and the EPC contractor. This includes Azito Energie deploying at least one fulltime dedicated HSE Manager during construction and the EPC Contractor deploying at least one HSE Supervisor to ensure implementation of the management program. While the EPC contractor is required to ensure adherence to applicable social and environmental requirements, Azito Energie will put in place detailed procedures to review and document EPC contractor compliance with national and ESIA requirements. Further, the Company will put in place procedures to ensure that corrective actions, where required, are implemented in a timely manner. While the management program has been outlined in the ESIA, Azito Energie will require the EPC contractor to develop a detailed HSE Management Plan consistent with the ESIA, IFC Performance Standard and Good International Industry Practices (GIIP).
PS2: Labor and Working Conditions
Employment
Azito O&M currently employs 36 personnel and the plant General Manager at the Plant. Further, Azito Energie has 11 persons in its employment. In addition to Azito O&M employees, 7 security guards, 5 cleaning/housekeeping staff and 5 restaurant/canteen staff, all contract workers, are also employed by Azito O&M. Post the implementation of the Project, the number of Azito O&M employees is expected to increase to approx. 50 persons. Azito O&M communicates the terms of employment through a Handbook (Réglement Intérieur), which is appended to all employees’ contracts. Azito O&M terms of employment/ working conditions relating to minimum employment age, minimum wage and, overtime and working conditions for contract workers are consistent with applicable employment/labor laws. Azito O&M is in the process of updating its Employment Policy Handbook to make it consistent with the group human resource policies in addition to the national employment/labor laws. Two delegates, two substitutes and one representative from the national energy sector unions are elected by the employees for entering into discussions with site management on employee issues. These meetings are undertaken on a monthly basis. Azito O&M enters into a Social Contract with the employees, which focuses on employee welfare measures. Azito O&M has a process of annual human resource compliance review and reporting to the Sponsors.
About 600 workers are expected to be deployed at the Project site during peak construction. The Company will follow a “no recruitment at gate” policy and will recruit as per a widely circulated recruitment plan. The EPC contractor has been required to adhere to applicable labor laws and to ensure that its sub contractors also comply with applicable labor laws. The EPC contractor will be required to ensure that it and its sub contractors provide living conditions for their respective workers that are generally consistent with IFC Guidance on Worker Accommodation.
Occupational Health and Safety
Azito O&M addresses health and safety in operations through the QHSE management system certified to OHSAS 18001 standards. Safety signage is provided, use of personal protective equipment is adequate and appropriate procedures for safety awareness and training to employees including contract workers is in place. The Company has a work permit system in place. Azito O&M has accident incident monitoring, investigation, reporting and corrective action processes in place. There have been no lost time incidents at the power plant in past 4 years. To ensure consistent and effective deployment, key safety related processes are also integrated into the Plant’s SAP system.
The EPC contractor will develop and implement a Health and Safety Management Plan (H&SMP), acceptable to Azito Energie and Azito O&M. The H&SMP will detail procedures for: provision of personal protective equipment and ensuring their use; training in the relevant hazards, safe working procedures and emergency response; provision of medical care, first aid, health monitoring, vaccinations, pest management and measures for prevention of disease spread; accident/ incident monitoring, investigation, reporting and corrective action; and periodic joint audits and corrective action. Further, during construction, no thoroughfare or access will be permitted in the operational parts of the existing power plant. The construction area will be completely isolated/ hard barricaded from the existing plant to prevent construction personnel from straying into the operational plant site. Access from the operational plant site to the construction area will be controlled through a single guarded gate. The EPC contractor has been required to deploy appropriately qualified supervisor (s) for effective supervision of compliance with the contractual provisions relating to labor working conditions. Further, Azito Energie will put in place appropriate procedures to obtain assurance on EPC contractor (and sub contractor) compliance with the labor working and living conditions requirements agreed in the EPC contract.
PS3: Pollution Prevention and Abatement
The Project is a resource conservation project as it will result in recovery of waste heat from gas turbine flue gas and increase the thermal efficiency of the power plant from approx. 29.5 to 44 percent. Moreover, the Project contributes to water conservation by opting for air cooled condensers.
The potential environmental aspects and impacts from construction activities for the Project include: fugitive dusts; noise; water consumption; hazardous materials and waste handling, storage and transport; sewage and domestic garbage treatment & disposal; surface runoff and sediment load management; and vehicle & vessel traffic. The EPC contractor and subcontractors are expected to control these to acceptable levels through application of standard construction environmental controls. The relevant recommendations and mitigation measures called for in the ESMP will be incorporated into the construction contract documents.
Air and Greenhouse gas emissions
No new combustion and emission source will be added on account of the Project. Stack emissions with natural gas have remained within the national standards and the then applicable World Bank Group (WBG) Guidelines. Dispersion modeling, covering all three phases of the Plant, was undertaken as part of the 1998 ESIA to assess impact on ambient air quality. In light of the fact that changes to Phase III Project since the 1998 ESIA are limited, the resulting modeling output is considered to be valid even now. The results of the model show that the impacts to ambient air quality resulting from gas-fired turbines in the Phase III plant configuration complies with the then applicable national standards, WBG Guidelines and also the current version of IFC EHS Guidelines (2007-2008). Diffusion tube ambient air quality monitoring data for the year 2001 (after commissioning of both the gas turbines) indicates that baseline concentrations of NOx and SO2 remain in about the same range as was predicted in the 1998 ESIA. Further, to minimize impact on air quality during construction: equipment will be maintained in good condition; number of trips of transport vehicles will be minimized; stockpile management to minimize fugitive dust; covered transport of earth or other friable/dust generating construction material; minimizing drop heights in unloading friable construction material; and wheel washing.
The Company will ensure that all air conditioning and refrigeration equipment as also fire safety equipment comply with the Ozone Depleting Substances phase-out plan of GORCI and Montreal Protocol. Total direct greenhouse gas emission (GhG) emission from Azito Power Plant is approximately 0.651 tCO2e/MWh and is expected to be 0.428 tCO2e/MWh after expansion. Accordingly, total direct annual GhG emission from Azito Power Plant is 2,040,990 tCO2e and GhG avoided on account of the Project during operation phase is expected to be about 728,000 tCO2e.
Noise:
During operation, noise emissions from the Phase III equipment will add to existing sources of noise from the: operational power plant; neighboring Foxtrot gas processing facility; and other noise sources in this peri-urban environment. Baseline noise levels are within national standards and IFC guideline limits during day time but nighttime noise levels exceed the applicable standards and guideline limits. Future ambient noise levels with the Phase III facilities have been predicted. Several noise abatement engineering measures, which will need to be implemented as part of the Project, have been identified in the ESIA so as to ensure that applicable noise standards and IFC/WBG EHS Guideline limits are met at sensitive receptor locations identified in the ESIA (the Azito and Béago villages and other sensitive receptors). The predicted increment in ambient noise associated with the Project compared to the current baseline is expected to be within 2 dBA. Further, the Company will discuss with ANDE, the ESIA findings related to noise from Foxtrot facility including the need for Foxtrot to implement measures so as to meet national standards at the identified sensitive receptors. During construction, potential sources of noise include construction equipment and temporary increases in traffic. Noise from construction equipment and increased traffic has been predicted at the nearest noise sensitive receptors for the noisiest phases of construction. This assessment indicates that the noise impacts associated with Phase III construction are expected to be within acceptable norms. In any case, construction activities will be undertaken only during day time and night time activities will be limited to low noise activities. Further, a process for timely disclosure of information relating to construction schedule and also a community grievance redress mechanism will be put in place in case affected communities have concerns related to noise or other aspects of the Project.
Water consumption
Current water consumption in the Plant is 14 m3/day of industrial water for operations and 7 m3/day for domestic purposes. Potable water requirement is met from the existing municipal supply and the industrial water requirement is met from the existing bore well of 45 m3/hr capacity. To meet industrial water requirements, water is pumped from the bore well to a 1000 m3 buffer tank (used also as fire fighting storage) and after demineralization, for compressor cleaning. These two sources will also meet the water requirement during construction of Phase III and subsequently during operation. The water needed for the construction phase of the Project is mainly related to the use of domestic water on site, in the temporary camps, and water consumption for the construction works. Water consumption from construction activities will be limited in quantities and in time. At peak construction about 110 m3/day of water will be consumed for domestic purposes and about 10 m3/day for construction, dust suppression and site maintenance. Municipal supply will be able to meet the required domestic water requirement or potable water may be trucked in and stored in tanks or the EPC contractor may be required to put in place a drinking water treatment facility. Incremental water consumption during the operating phase of the Project including for closed circuit steam generation, general use and fire fighting is expected to be 10 m3/day and incremental domestic consumption will be about 3 m3/day. Water from the bore well will be pumped to a new 1300 m3 tank. Both the existing 1000 m3 tank and the new tank will be connected. Studies indicate that salinity intrusion due to groundwater abstraction may not be expected. The Project’s impact due water consumption during construction and operation is therefore expected to be low. The Company will undertake benchmark testing of municipal water supply to confirm conformance to national potable water quality standards. Further, the Company will require periodic testing of water against national drinking water standards, in case it is to be trucked in or in case a treatment plant is setup during construction. A demineralization plant of 30m3/hr capacity will be installed to meet the HRSG feed requirements. The Company will implement a program to monitor water consumption, and identify and harness conservation opportunities.
The Azito Power Plant is located within 100 m of the Ebrie lagoon to the East and South. Impacts from construction and operation, if any, on the lagoon will be primarily related to potential contaminated drainage and runoff discharge in the lagoon and spills/contamination during barge based transportation activities. However, the impact on water quality of the lagoon during the construction phase is expected to be limited due to: small footprint of construction area (2 ha); implementation of good practice in site run-off management including through site surface profiling and provision of sediment traps in drains; prevention of untreated sanitary discharge into the lagoon; prevention of leaks or spills through appropriate handling procedures and provision of appropriate hazardous material storage (secondary containment etc.); stockpile management to prevent erosion; re-vegetation of slopes and minimizing stripped areas; and land cleared for construction related activities being restored to its original state. Further, the Company will ensure that appropriate marine transportation good practices are adhered to and lagoon sediment disturbance is minimized.
Currently, compressor washing water, boiler cleaning water and sanitary waste water are combined and treated through a chemical treatment facility. Oily water is treated through an oil-water separator. Treated waste water from biological treatment facility and the oil-water separator are mixed, equalized, pH treated and pumped to an evaporation pond (780 m3 maximum volume). When the evaporation pond gets filled (approximately twice a year), water is tested and if found conforming to Ivoirian guidelines for liquid effluent, is pumped outside the Plant premises on East perimeter and discharged on land about 30 m from edge of the lagoon. Most recent monitoring indicates that treated waste water meets IFC guideline norms prior to discharge and the Company will ensure continuing adherence to IFC/WBG EHS Guideline limits prior to discharge of treated wastewater. Storm water/surface runoff water is collected through the gulleys and surface drains into underground drainage and discharged on the West perimeter of the premises. Rain water collected from building roofs is also connected to this underground storm drainage system. Surface runoff from the transformer secondary containment is treated through an oil-water separator and discharged into the storm water drainage. Backwash of bore well water pretreatment filters is directly discharged to the lagoon. Wastewater during construction will primarily be sanitary wastewater from the construction camp, which will be treated in a mobile treatment plant to meet IFC EHS guideline norms prior to its discharge into the lagoon. During the operation stage, the key addition to waste water will be demineralization plant backwash, which will be neutralized in a dedicated sump and discharged to the lagoon. Significant increase in waste water is not expected on account of Phase III development. Post implementation of the Project, the treatment and disposal scheme for all wastewater, barring demineralization backwash water, will remain the same. The wastewater treatment will be modified to accommodate Phase III and will notably involve rehabilitation and protection of the evaporation pond, installation of a biological treatment unit, a neutralisation pond and an oily water treatment unit. The neutralization sump/tank will be provided with appropriate corrosion resistant lining.
Hazardous Materials
Hazardous materials at site include: Sulfuric acid (210 l); Caustic soda (60 l); Butane gas (bottles total 140 l); Gasoil/Diesel (200 l); Solvents (30 l); Lubricating oils (2800 l); Transformer oil (400 l); Natural gas (not stored at site but in the system); Diesel Fuel (12,000 m3); Acetylene (18 m3); and oxygen (22.5 m3). Significant increase in quantities of hazardous materials is not expected on account of the Project. The Plant has procedures in place for appropriate storage of these materials, including where required provision of secondary containment and access control. The quantities of sulphuric acid, caustic soda and lubricating oils are expected to increase to 30 m3 , 60 m3, and 5 m3 respectively. The construction of additional chemical storage facilities is proposed as part of the Project and the Company will ensure provision of appropriate acid/corrosion resistant secondary containment. The Company will ensure that during construction and operation, good site management practices are observed and that hazardous materials are properly stored and handled at site (i.e as appropriate within secondary containment etc.).
Solid Waste
Low quantities of earthwork expected as excavations required only for foundations and most of the excavated earth will be used for backfilling and site level increase to +4.5 m amsl. No existing structures are to be demolished except surface & underground drains at some locations within the premises and the existing warehouse (which will be rebuilt). Other wastes expected to be generated during construction include: household waste (organic waste at site and from labor camps), plastics, paper, food, packaging, office equipment, cables, scrap metal, paint cans, packaging, tin cans, glass, small amounts of other substances, and hazardous waste (including waste oil, oily rags, filter cartridges, absorbent materials, and batteries). Further, during operation phase also incremental waste generation is expected to be low and will be constituted primarily of packaging and general domestic waste, and low quantities of hazardous waste (primarily oil contaminated material). The Company stores all waste duly segregated, in a designated area and as required within containment. General waste during construction and operation will continue to be (as is the current practice) disposed through an independent waste management Company. This independent waste management company collects the waste periodically from the plant and disposes of it at Abidjan municipal waste dump. Some of the reusable waste/scrap is sold/handed over by the Company to scrap dealers.
Hazardous Waste
The primary hazardous waste during current operations include: the oil collected from oil water separators; sludge and residual solids from oil and grit separator tank; waste water treatment plant sludge; the evaporation pond sludge; and transformer oil from oil water separator. Separated waste oils, separated transformer oil and sludge are pumped by means of dedicated oil and sludge pumps respectively, to the site perimeter to be collected for treatment and disposal by an independent waste management company. This practice will be continued for post Phase III operation stage as well. Some hazardous wastes (e.g. toners, used batteries, bulbs, oil filter etc.), in relatively limited quantity, are being collected and stored on site for several years now because the Company has not been able to identify any accredited waste management company that treats and disposes these types of wastes in the country. The volume of hazardous waste during construction is expected to be of the order of a few cubic meters per month, which will also be disposed through the above mentioned industrial wastes recycling and disposal contractors. In any case, a detailed Waste Management Plan will be developed prior to the start of construction for proper storage and disposal of all wastes generated during construction. Capability to treat and dispose off the different types of waste in accordance with IFC/WBG EHS Guidelines and Ivoirian laws will be considered in selection of waste management contractors. A post-construction survey of the construction area will be conducted to confirm that all debris and wastes have been removed and appropriately disposed at the end of the construction phase.
PS4: Community Health, Safety and Security
The entire construction work and project activities will be within the existing facility except some lay-down area and labor camp, which will be located in part of the 300 m buffer zone. In the buffer zone, there is some limited grazing activity being conducted but no material impact on grazing activity is expected. Further, the Company will through access control, barricading, reflectors, signage, community safety awareness programs, and other measures mitigate the risk of accidents for the general public during construction.
Concrete for the foundations will be brought in from a ready mix concrete plant in Abidjan in concrete mixer trucks. Other construction material, mostly structural steel and sheets are expected to be transported to site both by barges and by road. During construction, up to 31 vehicle trips per hour are expected, the majority of which will be HGV''s. Transportation of equipment is proposed to be undertaken by road but there is a possibility this could be undertaken by boat or barges from the port of Abidjan, crossing the Ebrié Lagoon. Given the low number of loads compared to the traffic in the lagoon, and the fact that this option is temporary, impact from transportation of material by boat on fishing activities and on the lagoon may be considered low. However, the ESIA recommends measures to minimize community health and safety risk due to movement of vehicles/vessels traffic during construction and operation. Further, the Company will ensure that EPC contractors adopt good EHS practices during construction including: training of equipment operators and drivers in safe driving techniques; implementation of a personnel and materials movement plan to ensure that vehicle movement during construction has minimal impact on daily life patterns of nearby communities; speed controls; alarms; posting traffic marshals at high risk locations; undertaking appropriate measures to reduce fugitive emissions from storage and transport of construction and waste material; periodically monitor noise levels in potentially affected communities/villages; undertaking community awareness programs; informing marine authorities and fishing communities about barge movement plans; and adopting good marine practices during transport of equipment.
Azito village will benefit from influx of labor due to increased demand for attiéké, poultry, fish, farm produce, slaughtering activities, restaurants and recreation which constitute the main livelihood activities undertaken by Azito villagers. However, there may be increased volatility in local prices but this is expected to be short term. The Company will ensure that the worker accommodation conforms to good international industry and benchmark practices including those defined in the IFC/BRD Guidance on Worker Accommodation. Azito Energie will require the EPC contractor to develop a management plan that will include amongst other aspects, measures to minimize risk of community exposure to disease due to influx of laborers including: ensuring that appropriate medical facilities are available for all labor; a periodic health check up program; an awareness program on HIV/AIDS and STI; and measures to control disease vectors.
The Plant will develop and have in place procedures, trained personnel, and equipment for responding to emergencies, including explosion, fire, chemical spills and mishaps, accidental release of petroleum products, and medical emergencies. The Emergency Plans and procedures will be co-ordinated with emergency plans of Foxtrot and of the district authorities. Critical components of the emergency plan will be tested on a regular basis. Full scale emergency training exercises will be held every year including jointly with Foxtrot and district authorities.
Azito Power Plant engages 5 security personnel from a private security agency and four Gendarmes from the state security forces. While the Plant is provided with past records of private security personnel deployed, it will develop and implement procedures for ensuring that: security personnel have clear objectives and permissible actions laid out; security personnel are trained in avoidance of abusive conduct and handling various situations with clear procedures; security incidents are recorded, investigated and corrective action implemented; bona fide complaints against security personnel are investigated/disciplinary actions implemented; and there is a grievance mechanism for aggrieved members of the community or employees in the event of a violation of the code for security personnel.
