The findings of the IFC’s review and conclusions are summarized for each applicable PS in the paragraphs below. Upon implementation of the various mitigation measures currently planned by CGT, and with the Supplemental Actions identified by IFC and agreed with CGT, the project will meet the requirements under the IFC Performance Standards.
PS-1: Social and Environmental Management System
Social and Environmental Assessment:
The company retained ERM and carried out a series of environmental and social assessments for the project. In September 2006, the Environmental and Social Impact Study was completed based on the assumption that the project would use gas turbine technology. This study was further updated in November 2008 to reflect the change of technology from gas turbine to reciprocating engine. Because the project will be built in an existing thermal power station, additional soil and groundwater contamination studies were conducted in 2007 and 2008 to design contaminated soil remediation program: (i) Phase I Environmental Assessment, Lomé Thermal Power Plant, dated August 2008 and (ii) Phase II Soil & Groundwater Investigation, dated October 2008. The findings of the above listed assessment were presented to the Ministry of Environment in October 2008, and the company received an environmental compliance certificate from the Ministry in January 2009.
After the November 2008 environmental and social impact assessment, the project design was further modified to include a waste oil incinerator on site as an alternative to waste oil treatment and disposal off-site. ERM conducted a cumulative impact assessment of the generating facility and the incinerator and concluded that the operation of the incinerator be acceptable.
Adjacent to the CTL facility, there are 14 MW oil-fired emergency reciprocating engines (14 units of 1MW each) operated by CEET and 20MW oil-fired gas turbine facility operated by CEB. Considering that they are operated only on an emergency basis, an assessment of cumulative impacts of these facilities was not determined necessary. Besides, when the CEB 20MW facility will be converted to natural gas-fired, the cumulative air quality impacts by the project on natural gas the CEB facility are expected to be minimal.
Air quality impacts were assessed by using air dispersion modeling. When the project is using natural gas, the incremental ambient air quality impacts by the project are predicted to be small being in the range of 0.77% to 26% of the relevant ambient air quality criteria. When fuelled by HFO, which will be used until natural gas is available from the West Africa Gas Pipeline, predicted incremental ambient air quality impact levels are larger and may result in the levels close to the relevant air quality standards for NO2 and SO2. Appropriate monitoring programs are planned to address this.
As part of the environmental and social assessment, a hazard study was conducted by ERM to identify recommendations to mitigate potential hazards from the use and storage of HFO / DDO, and the delivery and use of natural gas. These recommendations are incorporated into the project design and will be implemented as part of construction work and operational emergency planning.
Management Program and Action Plan:
Based on the findings of the social and environmental assessment for the project, the company has established the three key environmental health and safety and social management plans: (i) Environmental Management Plan (EMP), dated May 2009; (ii) Phase II Soil and Groundwater Investigation and Proposed Management Plan, dated October 2008; and (iii) OHS Management System – Construction Phase, April 2009.
The EMP of May 2009 was prepared in line with IFC General EHS Guidelines, the Wärtsilä HSE Guidelines for Construction and Installation Work concerning power plant construction, the ERM HSE guidelines for the soil remediation activities, and the ContourGlobal Health and Safety Policy.
The company established Occupational Health and Safety (OHS) Management System for the construction phase of the project based on the ContourGlobal’s corporate-wide Occupational Health and Safety Policy. For the operational phase of the project, the company is preparing to establish an environmental and social management system to effectively implement the operational phase EMPs.
Organizational Capacity:
ContourGlobal (the sponsor) is providing social and environmental expertise and managerial support to CGT and the project. The company’s OHS Management System (Construction Phase) was established under the guidance of ContourGlobal OHS Director based in UK. The company’s series of environmental assessment conducted for the project with support by ERM was supervised by the ContourGlobal Technical Director, also based in UK.
The construction of the project is supervised by the company’s Construction Manager whose responsibility includes ensuring implementation of the environmental and social action plans for the project. The EPC contractor (Wärtsilä) has a dedicated Environmental, Health and Safety Manager on the construction site who reports to the company’s Construction Manager on a daily basis. During operation period, the company will appoint an Environmental, Health and Safety Engineer to coordinate and manage all the EHS aspects of the project. In addition, the company plans to establish a Health and Safety Committee which will be responsible for inspecting the facilities and making recommendations for improvements with regard to health and safety.
The company appointed a Community Liaison Officer to implement the ongoing public consultation and disclosure process, to oversee development and implementation of the grievance mechanism, to liaise with CGT site staff regarding implementation of any measures arising from the grievance mechanism, and to ensure that the public is regularly informed with respect to site activities, including any events with possible negative social impacts.
Training:
For the construction phase of the project, employees of the contractor and subcontractors are informed of the requirements of the ContourGlobal’s occupational health and safety plan and requirements through a series of toolbox meetings by the contractor’s health and safety supervisor. New employees of the contractor and subcontractors who will be involved in site work are receiving induction trainings on health and safety prior to commencing work. ContourGlobal Togo is in the process of recruiting around 40 employees for the operation of the project. The company’s Environmental, Health and Safety Engineer will ensure delivery of environmental, health and safety trainings to personnel within the project team.
Monitoring and Reporting:
As part of their Environmental Management Plans, the company has established environmental monitoring programs for air emissions and ambient air quality, effluent discharge, waste management (quantity, transport, disposal) and noise. When the project is fueled by HFO, which will be used until natural gas is available from the West Africa Gas Pipeline, predicted incremental ambient air quality impact levels are larger than the case of using natural gas and may result in the levels close to the relevant air quality standards for NO2 and SO2. The company plans to implement ambient air quality monitoring programs using diffusion tubes for NO2 and SO2 at six locations to ensure that relevant air quality standards are met during the operational phase of the project regardless of the fuel used. In case the monitored ambient air quality levels are determined to be exceeding the relevant standards due to the project, the company will implement additional mitigation measures, especially when the project is fueled by HFO.
With regard to the remediation of the contaminated soil of the CTL site, the post-completion monitoring programs will include installment of monitoring wells to monitor improvement of groundwater quality (twice-yearly monitoring during and after construction of the project). The company will also coordinate with the Togolese authority to prohibit the future use of the off-site private wells for drinking water purposes.
The company’s Environmental, Health and Safety Engineer will monitor the project’s environmental, health and safety performance to ensure that appropriate measures are being implemented in compliance with the Environmental Management Plans. In accordance with Togolese requirements, the company will prepare and submit periodic reports to the Ministry of Environment on the implementation of the Environmental Management Plans.
During the construction phase of the project, the CGT site management team is monitoring and measuring OHS performance of the contractors at monthly meetings. Any serious incident or an accident resulting in a fatality will be notified immediately to the company’s CEO and the CG OHS Director by the CGT Construction Manager. Safety statistics will be gathered on a weekly basis and reported to the CGT Construction Manager. In addition, internal site safety audits will be performance and the results and recommendations will be reported to the CG OHS Director.
PS-2: Labor and Working Conditions
The company will develop a local Human Resources (HR) policy in line with the Togolese labor law and IFC Performance Standards on labor and working conditions and will communicate this to all its employees upon taking employment. The HR policy will include CGT’s recruitment process, address non-discrimination and equal opportunity employment as well as employees: (i) rights under national law in particular wages and benefits, (ii) working conditions and terms of employment, (iii) rights to join a union and form collective bargaining agreements, (iv) grievance mechanism. Furthermore, CGT will hire a qualified person responsible for managing human resource matters.
Currently, there is only one CGT employee on the site and he is under the US CG human resource policy scheme. The other employees on the site (as of July 2009) include ten (10) Wärtsilä employees and approximately 150 subcontracted employees engaged in the preparation and construction phase, this number could rise to 200 to 300 during peak construction time. CGT has undertaken a due diligence in selecting a list of approved subcontractors to be used during the preparation and construction phase. During the operation phase there will be up to 40 CGT employees.
A satisfactory Occupational Health and Safety management system for the construction phase has been developed by CG internally. There is a dedicated Wärtsilä Environmental, Health Safety Manager on the CG site as well as a CG Construction Manager. Health and safety management plans and practices for the construction phase are satisfactory.
Wärtsilä, as the EPC, ensures that subcontracted employees are trained on a daily basis on occupational health and safety issues and checks are undertaken to ensure that persons under the ages of 18 are not employed at the site. Protective equipments are provided by the subcontractor. During site visit IFC observed that all workers on the site were wearing their protective equipment gears. A small health facility is provided by Contour Global with an on-site nurse provided by the subcontractor. Accidents, loss time injuries and near misses are tracked by the company. As of IFC visit in July 2009, there have been no accidents or loss time injuries since start of construction in May 2009 (54 consecutive days).
Evacuation plans have been posted at the facility entrance and more are to be posted within the site.
PS-3: Pollution Prevention and Abatement
Pollution Prevention and Resource Conservation:
Due to existing soil contamination of the CTL site as a result of prior hydrocarbon spillage/leakage, Phase I and II site assessments were conducted by ERM to establish a contamination baseline of the CTL site and to design remediation measures. Groundwater wells used by adjacent farmers were identified to exceed some of the drinking water quality criteria. Based on the findings of the Phase I and II site assessments, the company engaged ERM Remediation and Construction Management to carry out a contaminated soil remediation project with 2 million Euro budget. The remediation work started in May 2009 in coordination between Wärtsilä and ERM and is planned to be completed by February 2010. As of July 2009, Wärtsilä moved contaminated soil as part of the civil works to a temporary offsite location adjacent to the site. Several thousand cubic meters of contaminated soil from the 4.3 ha of the project site will be contained in the permanent containment cell (5,000 to 7,000 m3). ERM will also mitigate any further contamination from the existing CTL tanks and underground piping near the new project.
The ERM’s assessment concluded that the background ambient air quality levels of the project site is not degraded despite the fact that it is an industrial area. Based on this, the air emission levels of the project are designed to meet 50 mg/Nm3 (at 15% O2) for Particulate Matter, 2,000 mg/Nm3 (at 15% O2) for NOx, and the sulfur content of HFO is limited to maximum 1.5%, which are consistent with the latest World Bank Group Environmental Guideline limits of December 2008 – 50 mg/Nm3 for PM, 2000 mg/Nm3 for NOx from dual fuel reciprocating engines, and use of maximum 2.0% sulfur content HFO for SO2. The stack height of the project is designed to be 38 meters to enhance diffusion of air pollutants and to minimize incremental air quality impacts especially when HFO will be temporarily used until natural gas becomes the main fuel.
The project site is connected to the City of Lomé municipal water supply system which is planned to supply needed water for both construction and operational phases. In case the municipal water (quality / quantity) is found inadequate, a detailed study will be conducted concerning the sustainable extraction of site groundwater versus site needs, prior to any attempt to extract groundwater. The company will develop a site water conservation plan which will include elements such as regular monitoring of water consumption, installation of meters at water supply points and locations of major consumption, equipment of water saving devices for use of sanitary facilities.
Wastewater will be treated prior to any discharge by (i) septic tanks and biological treatment unit for sanitary water, (ii) oily water treatment unit for process water, (iii) linking rainwater discharges from the parking areas to the oily water treatment unit. Since there is no public drainage network in the industrial area where the project is sited, a clean water infiltration system is planned onsite (filter bed, infiltration dome) to be implemented down-hydraulic gradient of polluted zones. Wastewater will be monitored quarterly on pH, TSS, BOD, COD, hydrocarbons, total ammonia, total phosphorus, coliform, and other parameters (e.g. heavy metals) relevant to the operational phase when HFO is used.
The major noise source – engine room will be placed with as much distance as possible from the nearest receptors. Noise assessment modeling conducted by ERM shows compliance with the relevant ambient noise requirements.
Wastes:
Wastes generated during operational phase will include waste oils, recovery from secondary containment, residues derived from the centrifugation of HFO, sludge from the oily water treatment unit, used ion exchange resins, used engine filters, used batteries, laboratory waste, maintenance waste, containers and drums contaminated with oil or chemical substances, septic tank sludge, and office waste. Waste oil, ion exchange resins, filters and hazardous waste (laboratory waste, soiled rags) will be turned over to a company that specializes in the recycling, regeneration or disposal of such materials. Liquid waste will be stored with secondary containment to prevent risk of accident spillage. In addition, the company plans to install a small incinerator on site to combust oil derived from the bottom of oil storage tanks, residues from the fuel centrifugation process, and sludge from the oily water treatment unit. The incinerator is designed to process a maximum 3 tonnes of oil waste per day, and producing about 1 tonne of ash per year. Local disposal options of the ash from the incinerator have been identified in Lomé (a cement plant or a tile factory). If the quality of the ash is not acceptable to those facilities, the company will temporarily store the ash on site and find another solution for disposal which may include shipping to Europe for final disposal.
Hazardous Materials:
Hazardous substances such as chemicals for water treatment will be stored with secondary containment. Near and outside areas where acid is stored and handled, safety equipment will be provided, e.g. autonomous breathing protection equipment, extinguisher, a water station with abundant flow, safety showers and eye-wash fountains. Employee will be trained regarding chemical hazards.
Emergency Preparedness and Response:
As described in the section of PS-1, a hazard study was conducted to analyze potential hazards from the use and storage of HFO / DDO, and the delivery and use of natural gas, and various actions were incorporated into the emergency preparedness and response programs.
The company has prepared a brochure “Lomé Thermal Power Station, Visitors Guide, Ensuring your Health, Safety & Security”. This includes the Health & Safety Policy of CG Group, specific safety requirements for visitors, security considerations, key emergency telephone numbers, emergency procedures and a map showing the evacuation route and assembly points.
For the operational phase, the company will develop an Emergency Plan for the site and provide adequate training to employees and workers on the consequences of an explosion. Major emergency preparedness and response measures will include (i) adequate detection linked into the alarm system within the fuel tank bunded areas to provide the power plant operators with advance warning, (ii) active fire protection systems for cooling of fuel oil storage tanks and form pouring into the tanks, (iii) sufficient protection to the buildings so that employees can evacuate in the event of a fire to a safer location and locating exist doors in the buildings on the opposite side to the fuel oil storage tank where heat radiation will be the lowest, (iv) locating the fire water tank, fire protection pumping equipment container, and the fire protection form house in areas where they are not impacted by the heat radiation from a fire on site, (v) the gas supply pipeline be buried beneath the ground and adequate emergency shut off and manual isolation valves be provided inside the gas regulating unit, (vi) gas detection units within the gas regulation unit housing and in the engine hall around each of the engines, and (vii) “anti explosion” panels be installed in the engine hall and gas regulating unit housing to mitigate the impact of a potential confined gas explosion.
Other majors involving project affected communities are described in the section of PS-4.
Greenhouse Gas Emissions and Energy Efficiency:
The project is designed to have a high thermal generating efficiency of about 45% on natural gas and 41.8% on HFO (gross, HHV basis), with resulting CO2 emissions performance of 460 gCO2/kWh on natural gas and 700 gCO2/kWh on HFO. According to the latest International Energy Agency statistics, the average oil-fired power generation facilities in Togo emitted 798 gCO2/kWh in 2006. The project will be one of the most energy efficient and best GHG performing thermal power plants in Togo. The project is planned to generate about 780 GWh/year, emitting about 359,000 tonCO2/year if fueled on natural gas and 543,000 ton CO2/year on HFO. If the same amount of electricity is to be generated by the existing oil-fired power generation of Togo, the CO2 emissions would be 622,000 tCO2/year. Comparing these, the project is expected to reduce CO2 emissions from Togo by 263,000 tCO2/year if on natural gas, and by 79,000 tCO2/year if on HFO.
PS-4: Community Health, Safety and Security
Based on the hazard study conducted as part of the environmental and social assessment, the company is planning to implement various emergency preparedness and response actions (see PS-3 on specific measures) to mitigate potential hazards from the use and storage of liquid fuel oil and the delivery and use of natural gas.
Emergency preparedness and response actions involving project affected communities (farmers to the south of the site, small shop operators to the east, and the residents of the Kagomé village about 500m to the north) include (i) planning a safety zone in the immediate surroundings of the site (of at least 20m width), inside which any human activity external to the site be limited as much as possible, (ii) warning signs on the west and south facing boundary fences indicating the potential hazard and requirement to evacuate in the event of an alarm, (iii) coordination with the local fire department on the evacuation in the event of fire / explosion, (vi) preparation of emergency plans including evacuation of general public around the site boundaries where applicable, and (vii) provision of training for local people engaged in activities within the 20m safety zone identified in the hazard study.
The remediation of the contaminated soil being implemented as part of the project is expected to improve the groundwater contamination identified at some of the wells being used by the farmers located to the south of the project site. The EMP included an action to coordinate with the Togolese authorities to prohibit the future use of the off-site private wells for drinking water purposes. A follow-up action on this has been specified as part of the Supplemental Environmental and Social Action Plan agreed with the company.
PS-5: Land Acquisition and Involuntary Resettlement
The CGT project facility is located within the Lomé Power Station in an industrial zone near the Lomé Port. It’s surrounded by other industrial facilities to the North and West; small shops (food, hardware, fuel retailers) to the East; and small parcel of lands to the SE corner (approximately 1 hectare) used for agricultural purposes by opportunistic farmers. The small village of Kagomé is located approximately 500 m to the north of the site.
The project involved economic displacement of approximately 11 farmers who did not have title or rights to the land. The Lomé Port Authority handled the negotiations and transaction through cash compensation provided by ContourGlobal. Each farmer signed a receipt of the cash compensation in the presence of the Port Authority officials and CG representative. The vacated land was subsequently leased to CG for temporary use during construction.
There are potential plans to further economically displace approximately five small scale local food vendors located on the main road to nearby commercial stretch in order to construct another gate for the site. CG will engage in a consultative process with the vendors in coordination with the Lomé Port Authority and in accordance with Togolese Laws and IFC’s Performance Standards and ensure that they do not suffer any economic loss.
