Key environmental and social issues relating to the project are summarized below, along with specific information about how potential impacts will be addressed by the company.
Upon implementation of the featured mitigation measures described below and in the attached Action Plan, the project will comply with environmental and social requirements, namely the law and regulations of Colombia, IFC’s Performance Standards on Social and Environmental Sustainability and Policy on Disclosure of information, and applicable World Bank/IFC environment, health and safety guidelines.
PS1 Social and Environmental Assessment and Management System:
Social and Environmental Management System:
As the operator of the Rubiales oilfield, Meta Petroleum is responsible for the environmental, social, health, and safety performance of its own personnel and its contractors’. This is the reason why Termo Rubiales, as Meta Petroleum’s contractor, has to satisfy the requirements of Meta Petroleum’s management system.
Meta Petroleum has implemented an ESHS-MS (environmental, social, health and safety management system) that follows ISO 14001 and OHSAS 18001 standards and the company is expecting to certify this system by March 2009. The management system is well developed and the company devotes significant time and resources to achieve an outstanding E&S performance. Meta Petroleum exercises close supervision to verify that its contractors comply with specific EHS requirements. These requirements are included in the service agreement as part of Termo Rubiales contractual obligations.
Meta Petroleum assumes the responsibility of managing some key activities and programs like the preparation of ESIAs, environmental permits and licenses, solid waste disposal, EHS monitoring, and community engagement to ensure full consistency with its adopted standards.
A full-time EHS auditor on behalf of the Ministry of the Environment verifies compliance of contractors against the government approved EHS management plan and the license requirements, adding another layer of supervision to the project.
Termo Rubiales has adapted its own ESHS-MS to satisfy Meta Petroleum requirements. Key elements of Termo Rubiales EHS&S management system are described in the following sections. The fact that Termo Rubiales has developed a good management system, and that Meta Petroleum has effective EHS supervision oversight of its contractor, adds a significant level of comfort that Termo Rubiales will achieve a good EHS performance and compliance with the applicable Performance Standards. In addition the health and safety management records of Energy International (the parent company of Termo Rubiales) for projects of similar nature in other Latin American countries have been reviewed and it was noted that accident incidence is very low.
Social and Environmental Assessment: Colombia requires an environmental license as a pre-requisite to develop an oilfield. The Law 99/93 and the Decree 1753/94 have specific requirements for the environmental, health, safety and social impact assessment of oil and gas development and for the management plans to avoid or minimize those impacts. The law includes requirements for community engagement, emergency response, and environmental monitoring. The operator must present an ESIA to the Ministry of Environment and after this document is approved, the Ministry issues an environmental license that specifies the environmental and social conditions to be fulfilled by the project. The oilfield operator has the responsibility of obtaining the environmental licenses. In the case of Rubiales the license requires among other things, the presence of three different independent auditors (one for production activities, one for drilling activities and one for civil work activities) to verify compliance with the approved management plan and with the environmental license requirements. The Rubiales oilfield development plan had its environmental license granted in 2001. In 2008 Meta Petroleum presented an addendum to the original ESIA to incorporate the construction of new production facilities (including a new crude treatment plant, new production and injection wells, pipelines and the new power plant). Meta Petroleum as the oilfield operator has obtained all the environmental licenses and permits required for the new power plant with the exception of the so-called “specific environmental management plan” that will be presented to the Ministry of Environment in March 2009 as part of the environmental licensing requirement. Once this management plan is approved by the environmental authority the project is ready to get started.
Termo Rubiales has a procedure for the identification and assessment of environmental impacts and health and safety risks and has a master record with all the impacts and hazards and their associated risks.
A new export pipeline 235 kilometers long is planned to replace at least partially, a large fleet of over 700 trucks that transports Rubiales’ oil production by road. A different company will be responsible for the construction and operation of the new pipeline. The new power plant (the project) will sell the energy to Meta Petroleum which will then distribute this energy between the production needs and the pumping station that ships the oil through the export pipeline. This new pipeline is not considered as an associated facility because while the new pipeline would not be able to operate without the power supplied by the new power plant:
a) The new power plant will supply other oil field facilities on top of the pipeline pumping station.
b) Termo Rubiales sells the power to the oilfield operator (Meta Petroleum) who can use the energy at its own discretion.
c) Termo Rubiales will not have any formal commercial relationship with the pipeline operator, and therefore no influence over its management.
Management Program: As a contractor of Meta Petroleum, Termo Rubiales has to comply with a set of EHS&S requirements set forth in the contract signed between the two companies contained in a stand alone EHS&S annex. This annex requires that Termo Rubiales present in form and content acceptable to Meta Petroleum the following documents: a) an Environmental, Health and Safety (EHS) plan; b) a Health & Safety manual; c) a document with the description of EHS roles and responsibilities within the organization; d) an occupational health program; e) an EHS training program; f) key operational control procedures; g) a work permit system; h) a drivers’ safety program; i) emergency response and contingency plans; j) local recruitment and procurement program; k) specific EHS performance reports. All these documents were submitted in December 2008 to Meta Petroleum by Termo Rubiales for approval before construction commenced.
Action Plan: The company has proposed and agreed with IFC an Action Plan to address the gaps in its current E&S management system for meeting the requirements of the Performance Standards and of the applicable IFC EHS guidelines.
Organizational Capacity: The company will appoint an EHS engineer to supervise project’s performance, to coordinate actions with the oilfield operator, and to give support to project manager on EHS issues. The EHS roles and responsibilities of Termo Rubiales personnel are described in its Occupational Health and Safety Manual.
Training: The company has defined an Annual Training Program for all the employees working in the project. The program includes subjects related to environment, health and safety management. Given that the main risks are associated to safety during the construction phase, the program is stronger in areas like safety risks assessment, work permits, chemical storage and handling, and emergency response.
Monitoring: The company has a database to keep track of corrective actions issued, to facilitate follow-up and compliance verification. Most of the environmental monitoring activities will be administered by Meta Petroleum. Termo Rubiales will provide IFC with an air emission monitoring program, a GHG monitoring program and a noise level monitoring program according to IFC requirements (see Action 8 of the Action Plan).
Termo Rubiales will also prepare and implement an EHS internal audit procedure, to formalize the current audit practices (see Action 1 of the Action Plan).
Reporting: On a monthly basis Termo Rubiales will deliver an EHS&S report to Meta Petroleum that will include updates a) on environmental performance: the use of water, solid wastes generated, fuel consumption, management of chemicals, wastewater management, spills and clean-up activities; b) on the safety performance: accident performance indicators, training activities (including man/hours of training), vehicle safety, and follow-up of corrective actions; c) on occupational safety performance: incidence of illnesses, health performance indicators, preventive medicine activities, and occupational health training; d) on community engagement: percentage of national employees, percentage of local communities employees (non-qualified workers), money spent on local purchases, and money spent on local services. A yearly report based on the consolidation of these monthly reports will be provided to IFC as long as Termo Rubiales is the operator of the power plant (see Action 2 of the Action Plan). Meta Petroleum is in the process of preparing their internal environmental and social reporting with the objective of publishing a Social and Environmental report according to the GRI (Global Reporting Initiative) indicators.
PS2 Labor and Working Conditions:
Labor Conditions;
Termo Rubiales is required, through its contract with Meta Petroleum, to adhere to the labor conditions enshrined in the National Labor Law. In addition to this Termo Rubiales is required to pay all unskilled workers a minimum salary established by Meta Petroleum, which is double the national minimum wage (national minimum wage is 205 USD). Meta Petroleum has a procedure in place to ensure that all workers (permanent and temporary) hired by contractors and subcontractors are affiliated to the Social Security System as required by Colombian law. All unskilled labor will be hired from the in/directly affected communities through Meta Petroleum. Currently, Meta Petroleum employs 130 Indigenous Peoples.
The entire workforce for construction and operation will be contracted directly by Termo Rubiales. The workers required during construction will be hired on temporary contracts. It is expected that there will be 300 workers on site during the peak and 40 during operation. Workers are employed in shifts of 21 days in the camp and 7 days off. The working week during the shifts are 68 hours (10 hours 6 days a week and 8 hours on Sundays) Overtime beyond the national 40 hour week and work on Sundays and Public holidays is paid at a premium rate of 200%.
Termo Rubiales will provide transportation for their workforce to and from the Indigenous Peoples reserves and to Puerto Gaitan.
The current work force at Termo Rubiales is not unionized and it is predicted that the larger work force during construction will not be unionized either, due to the temporary nature of their employment. Termo Rubiales does have an informal grievance mechanism in place, which they will formalize (action 4, action plan). The Human Resource Policy of Termo Rubiales will be updated to reflect the ILO’s Core Conventions (action 3, action plan)
Labor camp:
During the construction of the power plant about 300 workers will be hired. The majority of these workers will live in the labor camp during their 21 day shift. Each dormitory module houses 25 workers in bunk beds separated by screens. Each module is 144 m2 and has its own sanitary facilities, television room and entertainment room in separate buildings. The labor camp is constructed in accordance with the requirements of the Ministry of Labor and Social Security.
Occupational Health and Safety: Termo Rubiales has developed for the project an Occupational Health and Safety Manual. The manual has a section dedicated to the identification and assessment of risks. The risks are classified according to its origin as: physical, biological, ergonomical, mechanical, electrical, chemical and stress-related. Every risk is assessed considering the number of workers exposed, the exposition frequency, the potential consequences, and the accident recurrence likelihood. The manual describes as well an on-site training plan, a safety inspection program, how to manage accidents investigations and records, safety performance indicators, different safe work procedures (like working on scaffolds, electric work, and heavy weight uplift), the work permit system, use of personal protective equipment, and the emergency procedures). EI Corporation, a parent company of Termo Rubiales provided a copy of its safety performance indicators for 12 similar power plant projects in the last 6 years and the indicators reflect good safety management.
PS3: Pollution Prevention and Abatement:
Pollution prevention:
The company prepared an environmental management plan based on the applicable recommendations included in the management plan of the Rubiales’ ESIA. This plan has provisions for emissions control, surface waters pollution protection, liquid effluents management, soil pollution protection, management of debris and excavation wastes, fuel storage and handling, safe operation and maintenance of heavy machinery, management of workshops and warehouses, solid wastes management, and environmental training for workers. The project will comply with the emissions standard referred to in IFC’s EHS Guidelines (Thermal Power: Guidelines for New Plants, July 1998). The new guideline for thermal power plants was released after the project was appraised and therefore is not enforceable. The power generators will be brought from another power plant and therefore they are not new. This equipment while able to comply with the new guideline emissions standards for NOx, SOx and particulate matter, would not be able to meet the new energy efficiency requirements for CO2 emissions. The potential impact is relatively very low in an open area with no population in the vicinity of the new plant.
However the engine power plant HFO-fired achieves higher energy efficiency than conventional steam power plants, and has the advantage of using much less water. Water for operational purposes will be provided by Meta Petroleum that has the necessary permits to abstract water for different uses. The fuel to be used consists of the Rubiales heavy oil which has a relatively low content of sulfide (around 1,2%). Another significant aspect of energy efficiency is the fact that because the power plant will supply a pumping station for a new export pipeline, it will dramatically reduce the current oil transportation by trucks (around 250 trucks daily) down to 40 %.
Wastes: Termo Rubiales developed a wastes management procedure for the project. The transport and final disposal of wastes outside the power plant boundaries is responsibility of the oilfield operator (Meta Petroleum). Solid wastes are classified in different streams including a) hazardous: like oily wastes, lubricants wastes, and medical wastes disposed of by incineration; b) organic wastes; c) recyclables: including glass, metals, paper, and tin; and d) office paper. The company will keep records of the amount of wastes generated per waste stream. The power plant will not require significant amounts of water for operational purposes (no cooling water is required) therefore the main wastewaters will be black and gray water. The company will install a wastewater treatment plant and the plant’s effluents will be disposed of by Meta Petroleum. Meta Petroleum has implemented a sound waste management plan that satisfies local regulations and IFC’s EHS guidelines. The plan includes a wastes monitoring program to ensure proper disposal.
Greenhouse Gas Emissions:
There will be no gas venting or flaring for operational purposes in the new plant. Most GHG gases will be generated as part of the power plant fuel combustion. The project is predicted to emit approximately 290,000 ton CO2 per year based on the assumptions of:
Plant Total Net Capacity: at least 57.0 MW
Annual capacity factor of 75% for the plant,
Electric generator efficiency of 97%,
Carbon emission factor of 0.765 ton CO2/Mwh.
Termo Rubiales will monitor thermal generating efficiency and annually quantify and evaluate GHG emissions performance for the project as referred by Action 8 in the Action Plan.
Noise: The operators are required to use hearing protection in areas of high noise level. No communities or households (that might be affected by noise) are located in the areas surrounding project activities. The company will implement a noise monitoring program as described in the action 7 in the Action Plan to protect its workers.
Emergency Preparedness and Response: The company has prepared a contingency plan for the construction phase, including fire and spill scenarios. Before the start-up of the power plant operation Termo Rubiales will develop the site emergency preparedness and response plans, including typical measures for reciprocating engine power plants fueled by HFO, to effectively respond to emergency situations to minimize risks and impacts to the environment and the surrounding facilities. A copy of the plan will be provided to IFC as required by action 5 in the Action Plan.
PS4 Community Health, Safety and Security:
Infrastructure and Equipment Safety:
All Termo Rubiale’s drivers are required to have a certification of attending a ‘defensive driving’ course on an annual basis and all trucks entering the oilfield are examined by Meta Petroleum. Termo Rubiales will be responsible for transportation of equipment to the sites.
Security:
All issues related to security of the oilfield are managed by Meta Petroleum. Energy International will not hire any armed security forces. Termo Rubiales will write a Statement of Principle on commitment to the Voluntary Principles on Security and Human Rights (action 6, action plan).
Health and Influx:
The workforce is not allowed to go outside the boundaries of the oilfield during the 21 days they spend working. All workers will undergo health examinations and are required to have Yellow Fever and Tetanus vaccinations. The policy on local recruitment for unskilled positions may expose the local and indigenous community workers to infections from the rest of the work forces. Termo Rubiales will monitor the health of their workforce and reports any issue on a monthly basis to Meta Petroleum.
PS7 Indigenous Peoples:
The project does not have any direct impacts on Indigenous Peoples, or on their livelihoods, land, physical assets and cultural property, and thus PS7 is not directly relevant. However the project is located in a region containing several Indigenous Reserves, including Unuma, El Tigre, Vencedor, Piriri and Walliani, and a number of employees are hired from these communities. The company will mitigate any possible adverse health impacts on Indigenous People by implementing vaccination schemes for their employees and by ensuring that workers do not leave the camp area. As part of their agreement with Meta Petroleum the company is required to give priority to employing workers from local communities. Currently Meta Petroleum is hiring 5-10% Indigenous Peoples and it is expected that the company will be hiring about 5% Indigenous Peoples during construction and operation.
