The findings of IFC’s review are summarized below for each applicable Performance Standard. Upon implementation of the various mitigation measures currently planned by WKPP, and with the additional actions identified by IFC and agreed with WKPP, the project will meet the requirements under the IFC Performance Standards.
PS1. SOCIAL AND ENVIROMENTAL ASSESSMENT AND MANAGEMENT SYSTEMS
Environmental and Social Assessment
With the assistance and services of qualified, experienced external consultants (CL Environmental Co. Ltd. and Golder Associates Inc.), JEP/WKPP completed the EIA process for the proposed development. In accordance with Jamaican Environmental laws and requirements, JEP/WKPP first prepared a Rapid Environmental Assessment (August 2008) which helped guide and frame the scope for the full EIA. Jamaica’s Natural Resources Conservation Authority (NRCA) also participated in determining the scope of the EIA, and managed the approval and public participation process. The approved EIA includes a description of significant expected environmental and social impacts, both direct and cumulative, and the recommended mitigation measures necessary to eliminate or minimize these consistent with the requirements of PS1.
As expected, the principal impact identified for the project is the potential to adversely impact the ambient air quality of the surrounding Hunt’s Bay Air Shed. Recently conducted continuous monitoring (at two stations from September 2009 to March 2010) indicates existing ambient air quality is within the Jamaican ambient air quality standards (JAAQS) notwithstanding contributions from existing sources such as the Petrojam oil refinery, the JPS Hunts Bay, JPS Rockfort, and the JPPC power plants. The analysis of air quality impacts on this non-degraded Air Shed of the proposed WKPP power plant relied on dispersion modeling conducted by Golder Associates, who appropriately followed the procedures specified in the relevant NRCA air quality modeling guideline document, as well as currently accepted modeling approaches used by the US EPA.
Management Program
The EIA will present the Action Plans for mitigating the impacts identified. The Plans will indicate the schedule and party responsible (i.e., WKPP or its EPC contractor, Wartsila) for implementing each of the mitigation measures during both the construction and operation phases.
Organizational Capacity and Training
The organizational responsibility to successfully undertake the implementation of the EIA Action Plans and to generally ensure performance of the project will be shared among the existing JEP organizational structure, the EPC contractor (Wartsila), and the WKPP Plant Manager at the time the plant begins operating. JEP’s Chief Technical Officer has overall responsibility for the planning and construction of the project, and is supported by an Environmental Manager and Engineering Services Manager in the implementation of specific environmental and social activities, as appropriate. JEP’s Human Resources Manager is responsible for coordinating all public participation and community outreach activities. As the EPC contractor, Wartsila will have a dedicated EHS supervisor on site. During operations, The WKPP Plant Manager will be supported by an EHS Specialist to coordinate relevant operating aspects. WKPP, JEP and Wartsila will ensure all construction and operating employees are informed of their respective EHS responsibilities and trained, as appropriate. Training methods will include health and safety induction training prior to commencing work, regular toolbox meetings, and periodic refresher courses.
Monitoring and Reporting
WKPP will establish monitoring and reporting programs for both the construction and operating phases of the project. Activities monitored during construction will include: construction vehicle movement, fueling and repair; erosion control and water quality; noise and dust generation; waste disposal; and employee health and safety practices. During operation, monitoring will include: stack air emissions and ambient air quality; noise; storm water and wastewater discharges; and employee health and safety. For each monitoring activity, specific parameters will be chosen to demonstrate compliance, and the frequency of monitoring will also be specified. WKPP will prepare and submit periodic reports of monitoring results to Company management and Jamaican regulatory authorities as required. Reports shall present numerical summaries of monitoring data, discuss exceedances and non-compliances, and indicate any corrective steps to be taken to prevent reoccurrence.
PS2. LABOR AND WORKING CONDITIONS
WKPP expects to employ 60 staff during the plant’s operation. Employees will be divided among the three main departments: Management and Administration; Operations; and Maintenance. They will be governed by JEP’s established HR policies and practices, which have proved to be effective in ensuring fair labor and working conditions for JEP’s existing 121 employees. Policies and procedures are compliant with Jamaican law and consistent with the requirements of PS2.
Employees will be provided with a written Benefits and Assistance Profile Summary that describes their rights related to wages and benefits. WKPP is committed to a Wage Administration Program similar to that of its affiliate, JEP, and designed to compensate employees on a fair and consistent basis and attract and retain a highly qualified workforce. It is the policy of JEP to pay wages competitive with the local and industry marketplace to equitably conduct performance and wage/salary reviews and adjust wages on a scheduled basis. The administration of JEP’s Performance Review and Wage Adjustment programs is designed and practiced to ensure consistency, objectivity and fairness.
There is a Problem Resolution Procedure to ensure fair and equitable treatment of all employees and to provide a process for employees to discuss and resolve employment problems. JEP is committed to effectively resolving employee problems brought to management's attention. The problem resolution process is available to all employees and is structured to address employment issues promptly and fairly.
JEP prohibits discrimination in hiring, training, compensation practices, promotion and dismissal of any individual based on gender, race and or color of skin, religion and political persuasion. The Company also prohibits the harassment of any individual based on gender, race and or color of skin, religion and political views.
JEP has a Social and Welfare Committee that consist of a representative from each department and the Human Resource Manager. The committee meets on welfare issues is also responsible for planning and executing of staff social event and team building activities within the organization.
Occupational Health and Safety
WKPP will develop and implement an occupational health and safety program relying on the successful policies and practices applied at JEP’s existing operating power plants. Employees will be provided with personal protective equipment (PPE), and procedures will be developed to ensure their use. They also will be properly trained in the relevant hazards, safety procedures and emergency response. Safety rules and guidelines will be established and regularly communicated to employees through internal circulars and training programs. All new employees will receive a basic safety and security presentation and regular training will be conducted for first aid and CPR, fire fighting, and emergency response. WKPP will ensure Wartsila and other construction contractors apply appropriate occupational health and safety plans and controls, including provision of PPE and appropriate training in safe construction practices and avoidance of hazards. Wartsila shall conduct regular safety inspections and track all incidents and loss time injuries during the construction phase.
PS3. POLLUTION PREVENTION AND ABATEMENT
Pollution Prevention and Resource Conservation
Pollution prevention and abatement issues of concern at the WKPP plant include: air quality; pre-existing site contamination; and noise. The EIA recommends a number of mitigation measures to minimize these and other impacts in both construction and operation phases.
Air Quality. Limited ambient monitoring suggests that existing air quality in the plant vicinity is non-degraded. That is, despite existing emissions from major sources like the Petrojam refinery and JPS’ Hunts Bay power station, among others, the JAAQS for sulfur dioxide, nitrogen oxides, and particulates – the key parameters of concern -- are not currently exceeded. Furthermore, modeling of the contributions of these pollutants from the proposed WKPP power plant predicts resulting ambient concentrations will remain in compliance with the JAAQS. Consistent with World Bank Group EHS Guidelines for new Thermal Power Plants, WKPP will ensure that the stack emissions of these pollutants do not exceed the following concentrations.
Pollutant Emission Limit
Sulfur Dioxide = 2.0% S in fuel
Nitrogen Oxides 1850 mg/Nm3
Particulate Matter 50 mg/Nm3
In keeping with the Company’s Air Quality Monitoring Plan, should WKPP’s monitoring of the Air Shed’s ambient air quality indicate JAAQS are exceeded, the Company will implement additional pollution control measures to mitigate this condition. Specifically and in the case that sulfur dioxide standards are exceeded, WKPP will switch to using fuel with sulfur content of not greater than 0.5%. Where ambient standards for nitrogen oxides (NOx) are exceeded, the Company will install a selective catalytic reduction (SCR) system, or implement other approved control measures, to appropriately reduce the concentration of NOx in the engine exhaust. The proposed stack heights for each of the 6 engines (32.5 meters above ground level) are consistent with Good Engineering Practice (GEP) Guidelines established by NRCA and the US EPA, and will enhance diffusion of air pollutants and to minimize local air quality impacts.
Pre-existing Contamination. Owing to its former use for a municipal wastewater treatment plant, some areas of the site contain waste, such as old treatment sludges, contaminated soils, and oily materials, which need to be removed and disposed prior to construction of the new power plant. Prior to initiation of site preparation activities, WKPP will conduct the necessary investigations to identify all contaminated wastes, soils, and other materials that need to be removed and disposed, and prepare a Closure Plan that meets Jamaican NEPA requirements.
Noise. Diesel engines of the type being installed at the site are significant noise generators. Although the industrial land uses immediately adjacent to the site (warehousing and light-medium manufacturing) are not noise sensitive, there are two schools and a residential community nearby (within a few hundred meters). Predictive modeling suggests that noise levels at these receptors will be in excess of allowable Jamaican and World Bank Group ambient guidelines unless additional mitigation is implemented. Consequently, WKPP will provide supplemental noise shielding and attenuation for the engines (e.g., masonry walls, insulation) to ensure noise is controlled to acceptable levels.
Hazardous Materials and Wastes Management
WKPP will have two (2) large fuel oil storage tanks with a total capacity of approximately 6,000 m3 for HFO and several smaller tanks and containers storing lesser quantities of fuels, lubricants, and maintenance chemicals. Areas where fuels or other hazardous materials are stored will be constructed within secondary containment structures to contain and prevent any leaks from being released to the environment.
Wastes generated during operations include waste oils, other maintenance wastes, lab wastes, and general plant trash. These materials will be suitably collected and disposed by licensed, commercial contractors. The plant will generate sewage, oily water from the plant floor and parking area, and reject effluent from the cooling water treatment system. Sewage and water treatment effluent will be discharged to the existing sewerage system operated by the National Water Commission. Oily water and any contaminated rainwater collected in tank containment areas will be treated in an oil/water separator and ultimately discharged to the existing municipal sewerage system.
Emergency Preparedness and Response
Storage and use of HFO at the facility presents potential hazards in relation to accidental spills, fires, or explosions. Consistent with NEPA requirements, WKPP will develop an Emergency Preparedness Plan, as well as an Oil Spill Contingency Plan. Specific measures will include: fuel tank storage alarm systems; engine hall alarm systems; and fire protection equipment. Employees will be trained in their responsibilities under each of these Plans. The Company will also coordinate its emergency response activities with the surrounding industrial activities and local communities.
Greenhouse Gas Emissions and Energy Efficiency
With an expected thermal generating efficiency of 42%, the resulting CO2 emissions performance of the plant will be 655 gCO2/kWh. Because the project is planned to generate 459 GWh/year, it will emit 300,645 tons CO2/year of greenhouse gases.
PS4. COMMUNITY HEALTH, SAFETY AND SECURITY
Fuel will be delivered to the site via a short pipeline from the nearby Petrojam tank farm, and/or by fuel truck from the refinery. While neither the pipeline nor trucks will pass through residential areas, the trucks will necessarily travel along a busy industrial road and the pipeline through the port area. Consequently, WKPP’s Emergency Response Plan (see above) will also include specific aspects and actions to mitigate the potential hazards associated with the delivery of fuel. It will include:
Emergency call lists of key outside parties;
Community liaison procedures;
Coordination with the local fire department in the event of a fire or explosion;
Evacuation routes, where applicable; and
Provision of emergency response training to these various parties.