The company has presented plans to address the environmental and social impacts to ensure that the project will, upon implementation of the specific agreed mitigation measures, comply with policies and standards internal to the HeidelbergCement Group, applicable national laws and regulations, IFC’s Performance Standards on Social and Environmental Sustainability and IFC’s applicable Environmental, Health and Safety Guidelines. The information about how these potential impacts will be addressed by the project is summarized in the paragraphs that follow, and in the Environmental and Social Action Plan (ESAP) which is disclosed with document.
PS 1: Social and Environmental Assessment and Management System.
Assessment. The new kiln in Tanzania, commissioned in 2009, and a new limestone deposit to be exploited in Gabon, both required an Environmental Impact Assessment (EIA) in accordance with national legislation. However, no other facilities have been subject to an independent environmental assessment given they were all established in the 1970’s and 80’s, when environmental assessments were not a regulatory requirement. More recently, and particularly since 2000, all of the Sub-Saharan countries in which the company operates have introduced environmental legislation. Thus new developments, such as the new clinker plant in West Africa, will be subject to an environmental assessment in accordance with national requirements. Equally, the company will assess new projects being considered in accordance with IFC’s requirements and HeidelbergCement’s Standards.
Management. The two grinding plants in Ghana are ISO 14001 accredited, while the facility in Tanzania aims to achieve certification in 2009. None of the remaining facilities has as yet a formalized EMS, with environmental and social issues addressed in an ad hoc manner. Nonetheless, the company has undertaken an internal review of the facilities in Gabon, Togo and Benin so as to develop an action plan for formal implementation of an EMS. The ESAP reinforces the company’s commitment to developing and implementing management systems, by requiring a formal EMS at all the facilities. In addition, the development of environmental management plans to address key issues such as fugitive emissions and stormwater management, is to be prioritized.
All the facilities have an on-site representative with a mandated responsibility for environmental management, which is generally allied to the management of occupational health and safety (OHS). The cement plant in Tanzania is the only facility with a fully dedicated Environmental Manager. This individual, along with the representative in Ghana, have received adequate training on EMS, and undertake environmental training for employees. Otherwise, additional capacity to manage environmental and social issues and train others in these issues is required. As defined in the ESAP, the company will develop a capacity building program such that all the facilities have adequate human resources to manage environmental issues.
Environmental monitoring is limited to stack emissions at the Tanzanian cement plant, and fugitive emissions at the grinding plants in Ghana. Equally, there are limited environmental reporting requirements, both internally and externally. Thus the company will develop a monitoring program for point source and fugitive air emissions and stormwater at all the facilities that is consistent with IFC’s requirements.
PS 2: Labor and Working Conditions
All the facilities have a detailed Human Resources Policy and / or Conditions of Agreement that clearly define employment conditions, and there are personnel at all the facilities dedicated to the management of human resources. All permanent staff i.e., approximately 1100, have defined contracts that comply with this Performance Standard. Employees at all the facilities are free to join unions, and there are written agreements with the unions at all the facilities. No individual below the age of 18 years is employed, which is verified at the time of employment by assessing personal records.
Additional contract labor is employed at the cement plant in Tanzania, all of whom have defined written contracts. Casual labor is employed at all the facilities, with the numbers varying, and generally based upon product demand. Non-core activities such as security and canteen management are outsourced.
Permanent employees are provided with additional benefits which typically include free meals on-site, transport to and from site, and access to medical care.
HeidelbergCement has an Occupational Health and Safety Policy which is applied to all the company’s activities. While none of the Sub-Saharan facilities have implemented a formalized OHS system, there are dedicated OHS representatives at all the sites. In accordance with HeidelbergCement’s standards, the facilities are in the process of establishing a schedule to develop and implement procedures to manage OHS. All employees have access to medical care which is either provided by an on-site clinic, or predefined medical facilities located in the vicinity of the respective plants.
Personal Protective Equipment is readily available to all employees, and at all sites the use of such equipment by employees was observed to be of a high standard. While OHS monitoring (e.g., dust, ventilation and noise), is not currently undertaken, the intention is to initiate monitoring as part of the OHS management system the company has committed to implementing at all the facilities. In addition, the ESAP defines the requirement for an independent OHS audit at all the facilities against accepted international standards, and a subsequent action plan to be agreed with IFC to address identified areas for improvement.
PS 3: Pollution Prevention and Abatement
Stack monitoring from the new kiln recently installed in Tanzania indicates that emissions for particulate matter and gaseous emissions comply with IFC requirements. However, the two old kilns did not. Thus the company has agreed that these two kilns will comply with IFC’s emissions requirements for particulate matter and, following further technical evaluation, the extent of gaseous emissions will be confirmed, in consultation with IFC. The kiln operating in Gabon requires repair to its electrostatic precipitator, as stipulated in the ESAP. Prior to construction, an Environmental and Social Impact Assessment (ESIA) to determine compliance with IFC’s Performance Standards will be undertaken for the new clinker plant in West Africa.
Greenhouse emissions, especially carbon dioxide (CO2), are mainly associated with fuel combustion and de-carbonation of limestone. Total greenhouse gas emissions from the current operations are estimated at around 860,000 tons CO2 equivalent per annum, as follows: approximately 47 % from the decarbonation of limestone, 33 % from the combustion of fuel, and 20 % attributable to electricity use. These figures do not take into account the transport of material to and from sites, which is outsourced. At all the grinding facilities the use of clinker is substituted with limestone and gypsum by up to approximately 30 %, thus reducing total CO2 production in the manufacture of cement. In addition, the company has committed to reducing the total quantity of CO2 produced per ton of cement in Gabon by replacing the wet process, or decommissioning the facility. In all countries except Gabon, plants’ specific consumptions of electricity and fuel are within good practice guidelines.
In Tanzania, natural gas and heavy fuel oil is used in the kiln, while electricity from the national grid is use for all other operations. In Gabon, a combination of petroleum coke, heavy fuel oil and waste oil is used in the kiln, with electricity from the national grid used for other activities. The grinding plants in Liberia and Sierra Leone use diesel generators for power generation, while in Benin it is a combination of generators and electricity; all the other facilities use electricity from the applicable national grid.
Fugitive emissions are an issue at all the grinding plants, key sources being uncovered stockpiles of limestone and gypsum, the offloading and loading of clinker, insufficient filtration equipment, and cement packaging. Except for one facility in Ghana which has accumulated excess clinker, all the facilities store clinker in enclosed sheds, with hardstanding areas. Various facilities are implementing mitigation measures to control fugitive emissions, notably during the offloading of clinker from vessels, and for the loading of clinker into silos given the potential high volumes of dust resulting from this activity, albeit for short periods. Fugitive emissions at the cement plants in Gabon and Tanzania are equally a concern and the situation, is compounded by unsealed areas, including roads, and limited quarry rehabilitation. Thus the company will implement fugitive emissions management and monitoring plans at all the sites, and rehabilitation plans for all quarries owned by the company. The latter is limited to the quarries in Ghana, Benin, Gabon, Tanzania and Togo.
The majority of stormwater drains at all facilities are open. Given the extent of fugitive emissions at the grinding plants, allied with extensive uncovered areas at the clinker plant and integrated cement plant, high sediment loads are deposited into stormwater drains. However, control methods are already in place at the grinding plants in Togo, Benin, Liberia as well as for one grinding plant in Ghana. At these locations, stormwater is discharged via settlement pits prior to discharge off-site. However, this control method is not efficient during high rainfall periods as it does not allow for the discharge of all stormwater via the pits prior to draining off-site. At all the remaining facilities, there are no settlement controls prior to discharge, which is either into municipal drains, water courses or ports. The ESAP defines the requirement for a stormwater management plan for all operations.
Waste water, including sewerage and canteen waste, is disposed of into septic tanks, aside from the Tanzanian facility where this waste drains to conservancy tanks for collection and disposal at the municipal waste water works. Thus a more appropriate method to treat waste water from this latter facility is to be defined and implemented.
Solid waste typically includes used refractory bricks, scrap metal, used oil containers and drums, and domestic waste. So as to ensure adequate management of on-site storage and disposal of waste, a solid waste management plan will be implemented at all the sites.
The facilities in Gabon, Tanzania, Sierra Leone and Benin have above ground fuel storage tanks, and bunding of several tanks is required. All the facilities have underground fuel storage. Fuel and lubricating oil (both new and used), at all sites is generally stored on sealed areas, however with no bunding. Thus a management plan for the storage and disposal of hazardous materials is to be implemented at all the facilities.
PS 4: Community Health, Safety and Security
Due to the nature of operations, dust is a nuisance, as opposed to a public health impact, and is often associated with clinker loading operations. In past years, several facilities have received complaints from neighboring properties, and national environmental authorities, in respect of dust emissions. In view of this, various mitigation measures have and are being implemented which, for the most part are associated with port operations. Implementation of the ESAP will further assist in limiting the potential impacts of the company’s operations on air quality.
While the facilities are located in areas generally suitable for such land use, they generate substantial traffic. For the most part, due to the facilities’ proximity to ports, the transfer of raw materials to the sites requires limited access to public roads. This applies also at Franceville in Gabon where raw materials are transferred by train to the grinding plant. Relative to the clinker and cement plants, they are located in proximity to the dedicated limestone quarries.
All the facilities have adequate internal and external vehicle staging areas. Therefore, the primary traffic risk to broader communities is as result of transferring cement from the grinding facilities, to customers. Aside from very limited transfer of bulk cement by the company, cement is collected by customers themselves, or sub-contractors. Thus, the company has limited control over this activity.
In some facilities the company uses armed guards. Where applicable, a protocol to govern the use of armed force in accordance with Performance Standard 4 and local requirements will be developed and implemented.
Assuming the new clinker plant in West Africa is located in a rural area, there will be the potential for the influx of outsiders, including truck drivers, contractors, and job-seekers, to result in the spread of sexually transmitted diseases, such as HIV-AIDS, into local communities. This issue will need to be addressed in the ESIA for the project so as to identify appropriate mitigation measures. In addition, the potential impact of traffic and emissions on adjacent communities will also need to be investigated and assessed.
PS 5: Land Acquisition and Involuntary Resettlement
Resettlement of some 20 families may be required to access the new limestone deposit identified in Gabon. Construction of the new clinker plant in West Africa may result in physical and economic displacement in the area where the new plant would be constructed. However, the extent of such displacement still needs to be defined. Finally, a significant number of individuals have inhabited land owned by the Tanzanian facility. Depending on the quality and quantity of the limestone deposit located in this area which is currently being evaluated by the company, this community may need to be resettled.
The ESAP defines the need for a Resettlement Action Plan that complies with IFC requirements in all instances where land acquisition and involuntary resettlement is required. Once more information is available, should the need for Broad Community Support and Free, Prior and Informed Consultation be identified as being necessary, this will be verified prior to resettlement commencing.
PS 6: Biodiversity Conservation and Sustainable Natural Resource Management
The potential impact on fauna and flora has been assessed for land required to access the limestone deposits in Tanzania, and the new limestone deposits in Gabon. The vegetation in the respective areas was not found to be sensitive, or of conservation significance. However, land as required for the proposed new facility may be inhabited with natural vegetation. The impact of this development on biodiversity will be assessed in the project ESIA. The latter is to be compliant with IFC’s Performance Standards, and the Terms of Reference and organization that would undertake the assessment are to be agreed upon prior to the assessment being initiated.
PS 8: Cultural Heritage
The EIA for the new kiln in Tanzania identified that while significant archeological artifacts were not identified on-site, these could exist in the area being mined for limestone. Thus the company will develop a chance-find–protocol for on-site activities. Relative to proposed site for the new plant, cultural heritage will be investigated in the ESIA for the project to determine the applicability of this Performance Standard.
