SOCIAL AND ENVIRONMENTAL ASSESSMENT AND MANAGEMENT SYSTEMS
JPS Co is aware of the key environmental and social risks surrounding the management of its aging power infrastructure, as well as the development of new generation assets, and has an appropriate assessment and management system in place to ensure adequate performance. Designed consistent with ISO 14001, the policies, procedures, organizational structure and other business process elements are currently being updated to reflect and incorporate Marubeni’s and TAQA’s (the new majority owners) corporate E&S management features and practices.
Environmental and Social Assessment
The Company uses a uses a range of recognized methods to identify environmental and social risks and impacts of its activities. With the assistance and services of qualified, experienced external consultants (MATEC Engineering and Consulting, CL Environmental Co. Ltd., Golder Associates Inc., and Environmental and Engineering Managers Ltd.), JPS Co has conducted audits of its existing operations and environmental and social impact assessment of the Munro Wind development against applicable Jamaican environmental and social laws and regulations. Audits focused on significant environmental, health and safety risks, as well as potential contaminated land liabilities associated with historical operations. The EIA’s provide detail on baseline environmental and social conditions, socio-economic data, applicable laws and regulations, impacts, mitigation measures, and EHS plans for both the construction and operation phases of the new developments.
JPS is in the process of completing the feasibility and EIA studies for the proposed Maggoty Hydro development. These studies will confirm the adequacy of the River flows to support an additional 6.4 MW of power generation while preserving ecological integrity. In accordance with Jamaican Environmental laws and requirements, the Company first prepared a Rapid Environmental Assessment (August 2008) which helped guide and frame the scope for the full EIA.
Going forward and reflected in the documentation for the updated management system, JPS Co will adopt IFC’s Performance Standards as part of the legal and other requirements that apply to Company operations.
Management Program
JPS Co has established and is managing a program of mitigation and performance improvement measures and actions for the E&S risks and impacts identified by the above-described analyses. This includes pollution control and hazardous material and waste management improvements recommended by the operational audits, and the project-specific action plans from the respective EIAs for the Munro Wind and Maggoty Hydro developments. The Company has also delineated the scopes-of-work and has budgeted the capital costs for provision of the equipment and resources to perform each action. These project-specific plans indicate the schedule and party responsible (i.e., JPS Co or its designated contractors) for implementing each of the mitigation measures during both the construction and operation phases.
Organizational Capacity and Training
At JPS Co., health, safety, security and environmental (HSSE) functions reside in one department reporting directly to the CEO. Human resources and external communications functions are managed by separate departments also reporting to the CEO. These support departments are sufficiently staffed with qualified, competent professionals, many of which hold advanced degrees. Within the JPS Co organizational structure, responsibility to successfully undertake the implementation of project-specific E&S actions and operational improvements is shared with core business units (e.g., generation, electricity delivery, etc.). Generally, the HSSE department focuses on planning, checking and monitoring activities, whereas the responsible business units are in charge of implementing specific actions on the ground, as appropriate. JPS Co.’s External Affairs Department is responsible for coordinating community outreach activities. The HSSE Dept. also ensures all employees and construction contractors are informed of their respective EHS responsibilities and trained, as appropriate. Training methods will include HSSE induction training prior to commencing work, regular toolbox meetings, and periodic refresher courses.
Monitoring and Reporting
JPS Co has established, robust monitoring programs in place for air emissions, wastewater discharges, solid and industrial wastes, noise, and worker health and safety compliance aspects of its operations. Within the HSSE Department, five staff are dedicated to these compliance monitoring activities. Periodically, monitoring results are reported to Company management and Jamaican regulatory authorities, as required. Reports present numerical summaries of monitoring data, discuss exceedances and non-compliances, and indicate any corrective steps to be taken to prevent reoccurrence.
Additional specific, recent monitoring initiatives completed or underway include: installation of ambient air monitoring networks in Kingston; soil and groundwater monitoring of land contaminated by spills of oils and chemicals; monitoring of equipment for oils containing PCBs; and noise monitoring of areas surrounding power generation plants.
JPS Co will expand its monitoring and reporting programs to include the Munro Wind and Maggoty Hydro projects. 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. For each monitoring activity, specific parameters will be chosen to demonstrate compliance, and the frequency of monitoring will also be specified.
LABOR AND WORKING CONDITIONS
The largest private employer in Jamaica, JPS Co.’s workforce totals approximately 1800, with 28 % representing management and professional staff and the remaining 82% technicians, general workers, and clerical and support staff. Reporting to the CEO, the Human Resource department manages the Company’s relationship with its employees. This relationship is governed by a robust set of policies and procedures that ensure fair labor and working conditions and are compliant with Jamaican law and consistent with the requirements of PS2.
JPS Co.’s Personnel Policies and Procedures Manual provides employees with a full range of information regarding working conditions and terms of employment, including: employment practices, hours of work, wages and salary administration, benefits and allowances, performance appraisal, discipline, grievance mechanisms, termination, training and development, communication, counseling, safety, security and disaster preparedness.
With the exception of 28 senior management staff, all employees are members of and represented by unions with collective bargaining agreements. As a result of some ongoing organizational restructuring, JPS Co. is currently engaged in process involving both voluntary and involuntary retirement for a select category of employees. For those employees who do not wish to voluntarily retire, the Company has a plan to effectively mitigate the adverse impacts, including: redundancy payments per the collective labor agreements, eligibility for insurance, full payment of accrued pension benefits, and provision of professional counseling support (i.e., financial planning, resume writing and career guidance).
The Company has an established occupational health and safety program consisting of a corporate policy supported by a series of procedures for employees across its generation and electricity delivery operations. Procedures cover: compliance and recordkeeping; training; incident reporting and investigation; hazard assessment and controls; communication; emergency preparedness and response; and inspection and audit. Employees are provided with personal protective equipment (PPE), and they also are properly trained in the relevant hazards, safety procedures and emergency response. JPS Co. also ensures 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. For the 2009 calendar year, JPS Co. reported: no fatalities; 9 lost time accidents; and 117 lost workdays by employees.
POLLUTION PREVENTION AND ABATEMENT
Pollution prevention and abatement issues for JPS Co. operations include: air emissions from its four existing thermal power stations; wastewater discharges associated with the Old Harbour and Hunts Bay power stations; and disposal of legacy PCB-containing equipment throughout the electricity transmission and distribution system. For the new Munro Wind and Maggoty Hydro renewable energy developments, the respective EIAs recommend a number of mitigation measures to minimize these and other impacts in both construction and operation phases.
Pollution Prevention and Resource Conservation
Recent monitoring data confirms that JPS Co. appropriately controls emissions of the key pollutants (sulfur dioxide, nitrogen oxides, and particulates) from its four thermal power stations in relation to applicable and relevant standards – both stack and ambient. There have been exceedances of particulates from the older, steam boiler units fueled by HFO at the Old Harbour and Hunts Bay stations. Nitrogen oxides emission levels from the gas turbines using LFO also occasionally exceed allowable stack limits at the Bogue Power station owing to instability in performance of the water injection control systems. Notwithstanding these exceedances, ambient levels of all three pollutants remain within acceptable levels in their respective air sheds, and pose no risks.
Part of the Environmental Action Plan agreed as a condition of IFC’s original investment, the improvements to wastewater treatment at the Hunts Bay and Old Harbour power stations have been delayed. The Company recently completed the final engineering designs for these new systems, and will install these in the near term. The capex for these is included in this prospective investment.
Key environmental impacts of construction of the Munro Wind and Maggoty Hydro developments – noise, soil erosion, traffic congestion – will be mitigated appropriately so as to eliminate or significantly reduce them. No significant operations-related issues are expected.
Hazardous Materials and Wastes Management
The Company is completing the process of phasing out and replacing aging electrical equipment (e.g., transformers) containing PCB-contaminated insulating oil. The procedure includes testing of oil and documentation of the proper treatment and disposal of oil and equipment found to contain PCBs consistent with internationally-recognized best practices. Any contaminated equipment and oil is removed from service and temporarily stored in a designated PCB warehouse. JPS Co. contracts with Tredi of France, an internationally-recognized commercial hazardous waste company, to dispose of the contaminated oil at their facilities. Capex for completion of this program is included in this prospective investment.
In general, transformers throughout the transmission and distribution system are installed on concrete foundations, but without secondary containment. Where containment is missing, JPS Co. will provide secondary containment structures for this equipment, both existing and new, to eliminate the chance of accidental spills of oil being released to soils, groundwater, and nearby surface waters.
Greenhouse Gas Emissions and Energy Efficiency
Based on the amounts of fuel consumed in 2009 and using IPCC estimation methodologies, CO2 emissions from JPS Co.’s existing thermal power stations totaled 2,290,335 tons CO2/year. This represents a Company-wide current carbon intensity of 767 g-CO2/kWh for thermal power generation.
COMMUNITY HEALTH, SAFETY AND SECURITY
The Company has a program that aims to educate communities about the hazards associated with accidental contact with electrical equipment in public areas (i.e. by children climbing in trees located near power lines, while retrieving kites, or by approaching fallen cables, etc) as well as safety measures for end users in the household (i.e. avoiding handling of connections on wet surfaces or keeping hands out of light sockets, etc). JPS Co. monitors the total number of accidents and fatalities associated with interactions between the community and the distribution infrastructure to help ensure the effectiveness of these education programs. The Company provides specific procedures and trains its employees in the safe operation all types of light and heavy-duty vehicles in order to reduce the rate of accidents.
The Company provides instructive information to communities in presentations or via the internet on such issues as the safe use of electricity in the home, staying away from broken transmission and distribution cables, avoiding illegal access into substations and other infrastructure by children at play, and other general safety precautions around electric installations. The loss reduction programs will have the added benefit of providing greater safety and reducing the risk of customer exposure to electrical hazards by standardizing household electrical wiring and providing secure and safe household connections to electrical supply.
The Company has a well-publicized emergency call-in number that is attended 24 hours a day, seven days per week, as well as service personnel available around the clock. There is a procedure in place to forward emergency calls to the appropriate public services in charge of emergency response when these are required based on the nature of the emergency.