The company has presented plans to address the potential 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 TICO, applicable national laws and regulations, IFC’s Performance Standards on Social and Environmental Sustainability and IFC’s applicable EHS Guidelines. A project Environmental and Social Action Plan (“ESAP”) has been developed to ensure potential impacts during the construction and operational phases are managed and monitored. TICO’s current operations generally comply with IFC’s requirements. In addition, the company has adequate internal capacity and experience to ensure effective implementation of the ESAP. The information about how these potential impacts will be addressed by the project is summarized in the paragraphs that follow, and in the ESAP which is disclosed with this document.
Environmental, Health, and Safety (EHS) Management and Organization
In 1995 an EIS was undertaken for T1 and the project received approval from the Ghana Environmental Protection Authority (“GEPA”). Subsequently, T1 commenced initial operations in 1999. In 1999 a Supplementary EIS was completed for construction and operation of T2 to its full capacity of 330 MW. The EIS was undertaken by GIBB (subsequently acquired by Jacobs), a large international consulting company with experience in the power sector and related environmental assessments. Thereafter, a Construction Permit was issued by GEPA for the T2 project and in 2000 the facility commenced operating in simple cycle mode. However, the Construction Permit lapsed in that TICO did not construct the final project stage, conversion to combined cycle. Thus in 2010, TICO commissioned Jacobs to undertake a supplemental EIS for conversion of the plant to combined cycle. This assessment was undertaken in consultation with GEPA and so as to comply with IFC’s Performance Standards. The EIS was compiled as a stand-alone document which incorporated studies from the previous environmental assessments, along with an analysis of potential environmental and social issues and associated impacts that may be significantly different from those previously reported upon. Thus while the EIS includes an overview of all the potential environmental and social impacts and related mitigation measures during the construction and operational phases, the focus is on impacts during operations, and primarily those related to air quality, noise and water supply and discharge. In addition to that EIS, a separate EIS was compiled by Jacobs for the once through cooling system for T1 and T2. This assessment also aimed to ensure compliance with national legislation and IFC’s Performance Standards.
The final EIS’s for the T2 expansion were submitted to GEPA for approval in October and November 2010 respectively. In December 2010, GEPA requested additional information on the EIS for the once through cooling system and submission of the permit and processing fees. The information requirements along with the permit and fees have been submitted to GEPA. Final approval will constitute issuance of a separate Construction Permit for conversion of T2 to combined cycle, and the cooling water system. In addition, GEPA have indicated that the Operational Permit for the T2 plant will require revision of the existing Environmental Management Plan (“EMP”) to reflect the T2 operations in combined cycle mode.
TICO has issued a tender for the project on an Engineering, Procurement and Construction (“EPC”) basis and the respective EIS’s have been made available to contractors tendering for the project. As per the contractual requirements, the EPC contractor is responsible for developing a Construction Environmental and Social Management and Monitoring Plans (“CESMMP”). In addition, the contract requires compliance with national occupational health and safety (“OHS”) legislation and international best practice. As defined in the ESAP, separate CESMMP’s will be compiled for conversion to combined cycle and the once through cooling system and incorporate the mitigation measures as defined in the EIS’s. TICO will undertake the internal auditing to confirm effective implementation of the CSEMMP’s, as will an independent third party.
The management of environmental issues and OHS is overseen by a dedicated EHS Department that includes an Environmental Engineer and Safety Officer. TICO is required to comply with the TAQA group procedures for EHS management and has a detailed EMP to facilitate compliance with group and national requirements. The EMP includes an EHS Policy, objectives and targets, and specific reference to compliance with national legislation and World Bank standards. Specific procedures to manage EHS are defined separately and include that related to welding and cutting, hot work, offloading of hazardous materials, handling and disposal of wastes, monitoring of air and water quality, spill response and accident investigation and reporting. Three months prior to commissioning the T2 expansion, TICO will update relevant EHS procedures to reflect activities associated with the conversion to combined cycle.
Training requirements are outlined in the Training Procedure and TICO implements regular training and refresher courses for all staff to ensure compliance with company policy and relevant legislation. This includes the storage and disposal of hazardous materials, management of accidental spills and emergency spill containment and cleanup. Thus there is a clear approach to EHS training; further information is provided in the subsequent section.
TICO is in the process of formalizing EHS management, including quality, by means of implementing ISO 14001, OHSAS 18001 and ISO 9001. A gap analysis and training for key personnel that will be responsible for implementing these certifiable management systems is currently scheduled for June 2011.
Annual, quarterly and monthly environmental reports are compiled for reporting on environmental performance and compliance with GEPA’s at approval requirements. These reports also include reference to any stakeholder engagement if necessary. This will similarly apply to the expanded operations and separate operating permits will be issued to T1 and T2 for the once through cooling water system with both operations having to report separately to GEPA on environmental performance.
Labor and Working Conditions
TICO has 66 permanent employees, of which 7 are women, operating on three shifts per day. In addition, there are 35 contractors and an additional 10 employment positions are envisaged as result of the T2 expansion. The company has a Human Resources Policy which is expressed in the form of a corporate creed. This is included in the Employee Handbook which applies to both permanent employees and contractors. All employees are provided with a letter of appointment which defines their title, job grade and salary, along with a hard copy of the Handbook. This document describes the conditions of employment, the leave policy, a grievance mechanism, applicable allowances and benefits, medical aid and statements regarding non-discrimination, amongst other issues.
TICO has a Human Resources Officer who is supported by the TAQA Human Resources Department. Ghana is a member of the International Labor Organization and has ratified 46 Conventions including those related to minimum wage, weekly rest, child labor, discrimination, freedom of association and collective bargaining. TICO review the personal records of potential employees to confirm their age and employees are represented by the Industrial and Commercial Workers Union of Ghana. All 37 junior staff are unionized and there is a signed collective bargaining agreement with the union which is renewed every two years.
Benefits provided to employees include free medical aid, inclusive of spouses and children, a housing allowance for individuals not residing on-site, a car loan at preferential interest rates, along with a fuel and maintenance allowance, child education grants and provision of a meal per day. Overall TICO’s labor practices are considered to be of a high standard and comply with the requirements of this Performance Standard.
Prior to employment, prospective employees are subject to a pre-employment medical examination and are required to undertake an annual medical examination thereafter. TICO has a full-time Safety Officer and has achieved in excess of 3,000 days (over 8 years) since a lost time accident; in 2010 there were only three recordable injuries. VRA have a hospital at TTPP and there is a dedicated TICO appointed doctor based at the facility. The hospital has a pharmacy, X-ray facilities and operating theatre, though anyone requiring surgery could be transferred to a hospital in Accra, the capital city of Ghana. There is induction training for all new employees, contractors and visitors alike. In addition, any worker who has been on vacation for 10 or more days is subject to refresher training. Regular tool box talks are held for employees and contractors and there is reporting on near misses and incident investigations are initiated along with corrective actions where necessary. All employees are provided with personal protective equipment (“PPE”) with the observed use on-site being very high. Safety signage is appropriately displayed throughout the site and is of a high standard.
There is a HSE committee that comprises representatives from all departments that meet every two weeks and undertakes inspections on occasion. In addition, there is a joint T1 and T2 safety committee that meets on an ad hoc basis.
The EPC contactor is required to define an OHS plan that is aligned with TICO’s internal requirements. This plan will be included in the CESMMP’s to be submitted to IFC for review. In addition, auditing is required to confirm implementation of the OHS plan and compliance to national labor legislation. Finally, workers accommodation will be provided in accordance with IFC’s guidelines and a description of how this is to be achieved will be included in the applicable CESMMP.
Pollution Prevention and Abatement
There is no change in emissions as a result of the T2 expansion; rather the emissions will be discharged at a lower temperature and at an increased height (main stack height of 60 m as opposed to the existing 10 m simple cycle stack). This is greater than the T1 stack height of 40 m so as to maintain the separation of plumes exiting the T1 and T2 units which occurs at present. Current operations comply with both the WHO and national ambient air quality standards and this is similarly the predicted result once the T2 expansion is complete. With both T1 and the T2 expansion operating on gas in combined cycle mode, the maximum predicted hourly ground level concentrations for nitrogen dioxide (NO2) is 154.5 ug/m3 which is 77% of the WHO guideline value (200 ug/m3). Under similar operating conditions, the average annual NO2 is predicted to be 25.5 ug/m3 which is 64% of the WHO guideline value (40 ug/m3). Thus with T2 operating as a combined cycle plant on gas the increase in annual mean ground level concentrations of NO2 above the current concentrations experienced is less than 5% of the WHO NO2 guideline. This finding similarly applies when the plant is operating on oil. This is considered significant given at least 95% of the emissions to air from the operations is NO which is oxidized to NO2 in the atmosphere. Shifting operations from oil to gas eliminates sulfur dioxide (SO2) and thus there is an improvement in air quality and equally there is a reduction in PM10 (“particles of 10 micrometers and less”) emissions.
The assessment of cumulative impacts as result of the future T3 operations predicts annual average ground level and hourly average concentrations for NO2 will be below the applicable WHO guidelines (40 ug/m3 and 200 ug/m3 respectively). Predicted annual average concentrations and hourly average concentrations of SO2 are well below the Ghanaian guidelines (50 ug/m3 and 700 ug/m3 respectively). There are no applicable WHO guidelines for these values. Maximum modeled daily average concentrations of SO2 are generally well below the Ghanaian guideline value (100 ug/m3) at all sensitive receptors (the highest recorded value is 53.8 ug/m3). Predicted emissions of PM10 as an annual average were all above the WHO guideline value of 20 ug/m3 and these values were recorded in a narrow range of 33-38 ug/m3; there is no applicable Ghanaian guideline. Daily average concentrations of PM10 are below the Ghanaian guideline (70 ug/m3) at all the sensitive receptors with minor concentrations levels above the guideline value at other locations. The WHO guideline value for daily average concentrations is 50 ug/m3. The high annual and daily averages and concentrations are however attributed to the high background concentrations used in the modeling which is unrelated to TTPP’s activities.
As identified in the air quality study, there is a need to update the air quality monitoring program to ensure it adequately reflects the current status quo. Thus as defined in the ESAP, TICO will undertake an independent review of the air quality monitoring program and agree with IFC on actions to address any deficiencies in the current program, should this be required.
During construction, potential air quality impacts could arise as a result of increased traffic generation, including dust generation from on-site activities. Increased traffic would have localized temporary impacts which are not considered significant, while implementation of mitigation measures in the CESMMP’s will address potential dust impacts. The CESMMP’s will include dust monitoring to assess impacts and thus guide the need for mitigation measures.
Monthly noise monitoring is undertaken on site at TTPP, at the fence line as well as at the VRA township and near the school in Aboadze. Day time average monitoring results from points within the Aboadze community and VRA Township are all below the prescribed WHO value of 55 decibels (“dB”) for daytime periods (07h00-22h00), and the related GEPA guideline value. The limited available night noise data available indicates average values of 43-48 dB in the Aboadze Village and VRA Township. These values are in general alignment with the WHO guideline value of 45 db for night time periods (45 dB), and in compliance with the GEPA guideline value.
The contract specification for the T2 expansion included the requirement to ensure that the noise level does not increase more than 3 dB above existing ambient noise levels at the fence line and the Aboadze monitoring station. To ensure the existing noise monitoring program adequately reflects the current baseline, TICO will commission an independent review of the existing program. Thereafter, an action plan will be agreed with IFC if required. Findings from the monitoring program will be used to guide the need for mitigation measures. Based on the current findings, this requirement is not anticipated, though this could change once T3 is in operation. However, this responsibility is largely assigned to VRA, as opposed to TICO.
Off-site noise related impacts during the construction phase are anticipated to be limited and primarily associated with traffic. This issue will be managed via implementation of the CESMMP, inclusive of noise monitoring.
T2’s raw water is currently supplied by the Ghana Water Company via the T1 dedicated freshwater reservoir. The existing service water requirement is 100 m3 per day and the potable water requirement is 20 m3 per day. T2 has a reverse osmosis (“RO”) water treatment plant that treats fresh water to produce demineralized water. This water is used to control NOx emissions generated by the simple cycle operations. The waste water from this plant is neutralized prior to release into a stormwater channel that discharges into a feeder stream of the Anankwari stream located adjacent to the plant.
Design of the water supply system for the T2 expansion will only be finalized once the EPC contractor is appointed. However, key elements will include two RO plants, a chemical clean lagoon and an ion exchange plant. One of the RO’s will purify sea water and the waste water from this RO plant will discharge to the cooling water outfall. The second RO plant will purify fresh water generated by the first RO plant. The waste water from this plant will be mixed with other plant discharges prior to discharge to the cooling water outfall. The chemical clean lagoon is used to store waste water from the acid clean / alkali boil out which is the final construction phase of the boiler. The method for disposal of this waste water will be confirmed with GEPA. Waste water from the ion exchange plant typically self neutralizes. The pH of this water will be monitored, the water neutralized if required, and then discharged into the Anankwari stream. The total additional water as result of the T2 expansion versus the facilities current water use will be an increase in the order of 10%.
Light crude oil is transferred to the TTPP site via a 4.5 km undersea pipeline to three 29,500 m3 storage tanks. Prior to use at either T1 or T2, the LCO is treated via centrifuges to remove the impurities, salts and water. The oily sludge that results from this process is transferred to an oily water separator system. When operating on oil, T2’s oily wastes are discharged to the T1 oil/water separator. This waste is eliminated when T2 is operating on gas. Sludge from the separator is sold to approved recyclers and the waste water discharged via the storm water drain to the adjacent wetland and the Anankwari stream. On-site water quality monitoring indicates compliance with the GEPA guidelines; these guidelines will similarly apply to the expanded operations.
Stormwater channels have been constructed around the site to collect uncontaminated stormwater. The stormwater discharges into a wetland area to the west which is part of the Anankwari stream. There will be limited additional stormwater as result of the T2 expansion, primarily due to an increase in paved areas and the administration building. There are no pollution controls or retention ponds prior to discharge as all stormwater from potentially contaminated areas is discharged to the oily water system. All sewerage from the TICO operations, including the staff housing, is discharged via the T1 sewerage treatment facility under an interim service agreement with VRA. The facility includes three sewage ponds which are designed to discharge via a storm water drain to a wetland west of the plant. However, due to the sizing of the system, no waste has been discharged from the ponds to date.
Solid waste is collected on-site with differing colored containers assigned for general and hazardous wastes. The waste is collected by the municipal authority and disposed of at their landfill which has a designated area for hazardous waste. T2 produces limited hazardous wastes though and includes used paint containers and material used in cleaning spills such as absorbent pads and oily rags.
There is an area located between TTPP’s southern boundary and the ocean that was previously used by VRA and T2 five years previously for the disposal of hazardous waste. This consists of a small pit some 50 m2 and 1.5 m in depth lined with HDPE. The surface of the pit is also covered with a HDPE liner over which soil has been backfilled. Whist this area is not perceived to pose a significant risk to public health or the environment, TICO will assess the site risks and agree on a remedial action plan with IFC if necessary. In addition, the company will undertake a Phase 1 due diligence to inform the extent of the potential contamination on site. This due diligence will also include land to be leased from VRA as required to accommodate the T2 expansion. This will assist TICO in defining current liabilities, including that related to newly leased areas. In addition, the findings will also inform the decommissioning plan as required in terms of TICO’s generating license. The various actions defined above are incorporated in the project ESAP.
The T2 expansion project will improve T2’s thermal efficiency. Currently the facility generates 0.96 and 0.65 grams of CO2 per kilowatt hour (“g/kWh”) operating on LCO and gas respectively. This will reduce when the facility is operating in combined cycle mode to 0.64 and 0.43 g/kWh of CO2 when operating on LCO and gas respectively. With T2 currently operating on LCO, the annual average CO2 emissions are 1,100,000 tons, and 734,000 tons when operating on gas (assuming partial load conditions). Once the T2 expansion is complete, the calculated annual average CO2 emissions from the facility will increase to 1,530,000 tons and 1,033,000 tons when operating on LCO or gas respectively (assuming base load operations). Installation of the once through cooling system increases the efficiency of T2 by approximately 10 MWe when compared to the use of seawater cooling towers for a similar quantity of fuel used. This results in a savings of 100,000 tons of CO2 per annum when compared to the facility generating a similar quantity of energy using cooling towers.
While various options for cooling were considered, the once through system is considered the most optimal. In addition to improving the plants efficiency, no cooling towers are required for T2 thereby limiting an increase in ambient noise levels. Further, as the existing T1 cooling towers will be made redundant, there is a possible noise reduction over existing conditions
The EIS for the once through cooling system included an assessment of potential impacts during the construction and operations with a detailed review of that related to marine ecology. Design of the system has taken into account the design parameters stipulated in the EHS Guidelines for Thermal Power Plants (2008).
The cooling system will abstract approximately 14 m3s-1 of sea water via the intake located approximately 2.5 km offshore at a depth of about 13 m. A similar quantity of water will be discharged via diffusers located some 1.2 km offshore and at a depth of about 8.5 m. Intake of sea water will be via a low velocity side entry structure so that water flow is at 90 degrees to the current. The intake velocity will be restricted to < 0.3 ms-1 to allow adult and juvenile fish to remove themselves from the influence of the intake current. Coarse screens will be located at the entrance to the intake to prevent large debris, mammals and reptiles entering the intake. Design of the diffusers for discharge will take account of the need for effective initial dilution and discharge upwards thus avoiding contact with the sea floor and minimizing potential damage to and from vessels.
Modeling of the thermal discharge indicates that at the edge of the mixing zone (100 m from the discharge point) the temperature will be less than the Ghanaian standard of 3 0C above the ambient temperature.
Aside from the increased temperature and intermittent chlorine, the water discharged will be unchanged from the source water. Chlorination of the water is required to limit biofouling and the water will be automatically chlorinated at pre-set intervals so as to achieve a maximum of 0.2 ppm free chlorine.
To confirm the findings of the thermal modeling undertaken as part of the EIS for the once through cooling and validate the extent of the mixing zone, verification modeling will be undertaken prior to sign off on the design for the once through cooling system. In addition, TICO will also develop and implement a program to monitor the physical and chemical parameters of the plant outfall allied to monitoring of the waste water in compliance with the IFC’s EHS Guidelines. These actions are defined in the project ESAP.
Community Health, Safety and Security
TTPP is situated within the Shama District which comprises a number of settlements the closest of which is Aboadze (1.5 km east of the TTPP) and Abuesi (3 km to the east of TTPP). Based on the 2000 population census, the combined population of these communities of some 19,000, though it is known that these communities have increased in size since the development of TTPP in response to direct and indirect employment opportunities. The primary economic activities of these communities is fishing and farming.
Aside from the shoreline and marine activities, all construction will occur within the boundaries of T2 and key potential impacts on communities relate to traffic, air quality and noise. The shoreline is a right of way and the EPC contractor is required to ensure site safety and security and this area will be maintained as a right of way. Road access to the site is not required via community residential areas, though the communities do use the primary public access road to the site to access the main road leading to Takoradi. Traffic will be managed during construction via implementation of the CESMMP’s. There are specific conditions in the EPC contract to manage labor and the potential for increased community exposure to disease is not anticipated due to an influx of labor. TICO and VRA have good relations with the community and there is open ongoing dialogue between the parties. Given the existing communications channels allied to those to be implemented during construction, community grievances should be rapidly addressed.
VRA has a comprehensive emergency and preparedness plan that also addresses the potential for offshore spills as a result of offloading LCO via the marine buoy. To ensure alignment with the broader TTPP operations, T1 and T2 convene an annual fire drill. In the event of a fire, the fire fighting system includes a fresh water fire system, a seawater (stand-by) system, a foam system (for fighting oil fires) and a CO2 system. Fire hydrants are located at strategic points throughout TTPP and there is a dedicated fire department with a fully equipped fire tender. The Ghana Fire Department may also be called upon to provide support if necessary. Prior to project completion and as per the ESAP, the emergency response plan will be updated. The EPC contractor is also required to define an emergency response plant for inclusion in the CESMMP’s.
On-site security is provided by unarmed guards who may call on the Ghanaian police if required.
