PS1: Social and Environmental Assessment and Management Systems
Environmental and Social (E&S) Assessment
CAPSA has programs in place to prevent and reduce emissions, wastewater, soil contamination, and solid waste. The company also has preventive maintenance programs and a continuous improvement approach to enhance its E&S systems to ensure all established procedures and requirements are followed. CAPSA commissions either environmental and social impact assessments and/or environmental audits to assess E&S impacts when new operations/activities are implemented. Currently, the company is up-to-date with all local environmental requirements. As part of the management of its operations, CAPSA conducts periodic internal audits and analyses and implements the audit recommendations.
Management Program
CAPSA continues implementing its Environmental, Health and Safety (EHS) Integrated Management System based on ISO 14001 and OSHAS 18001 standards. The company has completed the implementation of general operational and management policies, standards and procedures, the implementation of certain specific procedures related to some minor tasks are still pending. As part of this project, the Company has committed to develop and incorporate a social component into its EHS Management System in accordance with the IFC Performance Standards and international best practice as indicated in the ESAP.
Organizational Capacity
CAPSA has a dedicated environmental, safety and social department to ensure the operations comply with local EHS requirements, CAPSA’s corporate EHS initiatives, and IFC requirements. The EHS coordinator, who oversees EHS activities of all CAPSA operations, reports directly to the General Manager. CAPSA also has a team of five full time specialized staff. Three of the staff are dedicated to environmental issues while the remaining two are dedicated to safety issues. The entire team is also responsible for community engagement.
Training and Monitoring
CAPSA has programs in place to periodically train its own employees as well as contractors on environmental, health, and safety aspects aiming to minimize/avoid workplace accidents/incidents.
The company also has monitoring programs in place to assess its EHS performance. Currently, CAPSA monitors noise, domestic liquid effluents, solid waste generation, as well as the number of accidents/incidents. CAPSA has a system of independent monitors that conduct annual supervision audits of the operations, and prepare annual monitoring reports for the local environmental authorities of the province of Chubut and for IFC.
Grievance Mechanism
Grievances from the community are communicated to the company through the company representative in the community. Once grievances are received by the company, they are handled and resolved. The company maintains records of the grievances and response actions. As part of this project, CAPSA will strengthen its community grievance procedures through enhancing outreach to local community members and provide them with information on ways to channel grievances and expected response time. The details of the upgrade of the grievance mechanism will be provided to IFC as required in the ESAP.
PS2 Labor and Working Conditions
Human Resource (HR) Policy and Management
CAPSA has a Human Resources (HR) manager who is in charge of implementing the company’s HR policy and systems for all its operations including training protocols, work conduct, employee competencies models, mechanisms to handle and resolve employees and contracted laborers grievances, etc.
Non-Discrimination and Equal Opportunity
The company is an equal opportunity employer. All hiring and promotions are merit-based.
Protecting the Workforce
There is no child or forced labor in any of its operations. In addition, the company ensures that employees as well as contract laborers are at least 18 years old.
Working Conditions and Terms of Employment
In addition to compliance with in-country labor laws regarding salaries, hours of work and contribution to social security, the company provides additional benefits to its employees (i.e., extended health insurance to employees’ families, annual bonus, additional salary (14th.) The local authorities conduct periodic labor audits.
Workers Organizations
CAPSA employs approximately 44 people in Buenos Aires, 125 in Comodoro Rivadavia and approximately 650 contract workers, from 45 different contractors. As per Argentinean law and the HR Policy of the company, all employees have the right to association. Currently approximately 65% of the contract workers are unionized while none of the direct employees are unionized. All workers (own and contractors) can submit grievances in dedicated boxes placed for that purpose. All submittals are reviewed by management bi-monthly and all decisions and actions taken are documented. CAPSA has committed to strengthen the grievance mechanism, as indicated in the ESAP, by providing the option of anonymous filing grievances through a phone line and providing all workers with information about the grievance mechanism procedures (including response time, committee that resolves grievances, workers’ representatives in the grievance committee).
Occupational Health and Safety (EHS)
CAPSA has appropriate medical services for all its operations and conducts regular medical check-ups for all direct employees, according to the national regulations, provides personnel protective equipment to its employees and requires their use at all times. CAPSA has a low accidents/incidents rate and has not had any fatal accidents.
The Company has response equipment and trained personnel, available at all times, to handle emergencies. Each operating field has its own contingency plan that identifies critical areas, controls and responsible personnel that covers emergency response, communications, and detailed measures to be taken in the event of a spill or accident. Also, as part of its continuous improvement program, CAPSA will ensure that all its operations have industry-best safety measures/systems (i.e., double containment wall for storage tanks, impermeable floors in areas were oil is handled, leak prevention procedures, etc.).
CAPSA’s key H&S programs include: (i) assessing employees’ general and occupational health, (ii) evaluating work-related risks and prevent occupational impacts, and (iii) implementing preventive/corrective measures to reduce negative EHS impacts.
PS3: Pollution Prevention and Abatement
CAPSA conducts all operations with an emphasis on minimizing environmental impacts by reducing the likelihood of leaks and accidental spills. CAPSA puts strong emphasis on conducting predictive, preventive, and corrective maintenance.
Raw Materials and Resource Consumption
All gas generated at the production wells is used to produce the energy needed by the operations. All water needed is obtained from authorized water wells. There is no negative impact to nearby communities from the groundwater use for current company operations. As part of this project, CAPSA will increase its water consumption in 10,000 m3/day; this water will be obtained from the reservoirs producing hydrocarbons in the area. Thus, it will not negatively impact the aquifers water capacity from which the water is obtained.
Air Emissions, Liquid Effluents, and Ambient Conditions
Since all gases generated during production are collected to generate energy needed on site there is no gas flaring. Fugitive emissions from the storage tanks will continue to be controlled as indicated in the ESAP.
At both fields, Diadema and Km 20, the Company injects production water into the wells it has prepared for this purpose. Thus there is no process discharge water making it a zero discharge operation. Domestic and storm waters are disposed of in septic tanks which are serviced regularly. The type of polymers used in the CAPSA’s Project are used in different industries, particularly in water purification as well as in paper manufacturing and enhanced oil recovery (similar to CAPSA’s project), therefore it is not expected that there will be negative impacts in zones involved in the Project.
The Company has programs in place to control erosion on steep slopes and in areas with soil erosion as well as a revegetation program for abandoned wells and new well sites. It has also installed protective devices (mesh, fencing) to avoid the trapping of animals, particularly birds, in open basins and reservoirs.
Solid and Hazardous Wastes
The Company has a solid waste management system in place. Hazardous and non-hazardous wastes, including those from the clean-up of septic tanks, are segregated and disposed of properly, following local requirements. As part of its continuous improvement approach, CAPSA also looks for recycling alternatives of its residues. CAPSA has eliminated the use of PCB equipment from its operations and is currently working on final disposal as indicated in the ESAP. The Company has applied for the permits to export PCBs and is waiting the authorities to complete the process. The Company has already contacted international suitable companies to properly dispose of these wastes.
Operational Safety
CAPSA has established procedures to ensure the safety of its operations. It has detailed procedures for the handling and storage of hazardous materials including polymers to be used as part of the project. CAPSA will update its procedures, as needed, to ensure applicable measures are in place for safe handling and to prevent employee exposure to polymers. All process installations have leak detectors, and audible alarms. Chemical storage areas have containment walls. The Company will complete installation of spills/leak containment walls on the remaining storage tanks and chemical storage areas as indicated in the ESAP. The company will continue to replace old pipelines to reduce the number of spill and leak incidents.
Fire and Oil Spill Prevention and Emergency Response
For each operational site, CAPSA has developed and established Oil Spill Prevention and Emergency Procedures and Plans to properly respond in the event of any emergency. Key elements of these plans include procedures for internal/external communications, response organizations/contacts, emergency equipment, emergency training procedures, etc. As part of the prevention/response programs, CAPSA has trained fire/emergency response brigades available at all times, conducts periodic emergency response drills, has installed alarms, sprinklers, signals, hydrants, dedicated fire water tank and extinguishers throughout the plant, etc.
Greenhouse Gas Emissions(GHG)
CAPSA’s GHG emissions contribution is low, since they do not have gas flaring to the atmosphere.
PS4 Community Health, Safety and Security
CAPSA operations are built to reduce risks to nearby communities, which are located at approximately 500 m from any production well and 4.25 km from the processing plant. The company has also established maintenance and monitoring programs and conducts periodic emergency response drills. CAPSA also extends its safety approach to nearby communities. Specifically, the Company donated an ambulance to the local hospital and has a firefighting truck and a fire brigade which can be used by the community of Diadema if necessary. The Company has also either relocated (production plant) or closed (production wells) operations that were in vicinity of the community of Diadema to minimize risks to the community.
Revenue management by local municipalities
CAPSA pays fiscal royalties to the provincial government as per local regulations.
Conclusions:
Accordingly, IFC concludes that the proposed project will meet the applicable IFC environment and social performance standards and the environmental, health and safety guidelines upon successful implementation of the agreed mitigation measures listed in the ESAP.
IFC will evaluate the project’s compliance with the applicable environmental and social requirements during the lifetime of the project through the following methods:
- Review of the annual monitoring reports (AMRs) prepared for the project;
- The status of implementation of any measures contained in the ESAP;
- Ongoing performance of project-specific environmental, health, safety, and social activities;
- Periodic site supervision visits will also be conducted, if necessary.
