Key environmental and social issues associated with these power plants include the Project Companies’ and contractors’ capacity to undertake adequate mitigation measures commensurate with the adverse impacts, and in consultation with locally affected populations, during both construction and operations phases, particularly with regard to: i) surface water resources; ii) fair, safe and healthy working conditions for both construction and operations work force; iii) wastewater, solid and hazardous waste; and iv) impacts of construction and operations on the natural flora and fauna of the project area and the human populations surrounding the project area. Information concerning how these potential issues will be addressed by the Project Companies in the construction and operation of its CSP plants is summarized in the paragraphs that follow.
PS1: Social and Environmental Assessment and Management System
IFC’s assessment considered: The Project Companies’ management of its environmental, health and safety performance in the establishment and operation of its facilities; and compliance with national and local permitting requirements.
Environmental Assessment: South Africa has the most comprehensive EIA and impact management requirements in all of sub-Saharan Africa. The EIAs for each of the power plants have been undertaken by well reputed consultancies and technical specialists, each EIA is of an international standard and both have been granted their requisite authorizations by the Department of Environmental Affairs (DEA).
The overall assessment for each power plant, as well as associated specialized studies, follow the standard protocol of studies of this type to establish the nature, extent, duration, magnitude, probability and significance of potential impacts. In addition to a general assessment of impacts, each EIA contains specialized assessments of impacts on the ecology, avifauna, geology and soil conditions, hydrology and water resources, cultural heritage and visual impacts of project infrastructure. Each EIA contains a comprehensive socio-economic profile of the areas and consideration of both negative and positive impacts, including cumulative impacts, and a full record of public consultation and comment.
The most significant environmental impacts associated with the proposed power plants identified by the EIA studies include impacts on water resources and visual impacts on the natural scenic resources of the area due to disturbance and modification of the site, and the presence of construction workers on site. The studies conclude that: i) there are no environmental fatal flaws that should prevent the Project from proceeding; ii) the predicted ecological impacts are of medium to low significance; and iii) the local employment benefits offered by the construction and operation of the Project outweigh the potentially negative social impacts. The studies conclude that, subject to the implementation of recommended mitigation measures, each of the power plants will comply with the requirements of the DEA.
Management, Monitoring and Reporting: Each power plant EIA includes a comprehensive Environmental Management Plan (EMP) that outlines measures to be implemented for the planning, construction and rehabilitation, operation and decommissioning phases of the plant so as to manage and minimize the extent of potential environmental impacts associated with the facility over the life of the Project.
The EMP for each CSP plant summarizes appropriate management plans to control air quality (e.g., dust management), erosion and sediment, soil contamination, spill incidents, impacts on terrestrial ecology, water quality, noise and vibrations, traffic and transportation of materials and equipment and waste management during construction and operations.
The EMP for each CSP plant is structured to ensure compliance with the requirements of all environmental authorizations, permits and obligations established by the relevant environmental legislation. In addition, each EMP incorporates the recommended mitigation measures identified in each of the EIA specialized studies (ecology, avifauna, geology and soil conditions, hydrology and water resources, cultural heritage and visual impacts of project infrastructure) into a set of actions and/or controls – each with its specific performance indicators and monitoring regimes – to ensure adequate impact mitigation at each of the Project stages. Each EMP further identifies personnel responsible for implementation of each action and the timeframe in which those actions must be implemented.
The Project Companies will appoint a Project Manager and Site Manager for each CSP plant. These managers have environmental management responsibilities incorporated into their terms of reference that include familiarity with the EIA, EMP and the requirements of the DEA’s Authorization, as well as responsibilities to ensure that engineering contractors and service providers observe all environmental and social impact mitigation provisions detailed in those documents. These managers will be supported by an Environmental Control Officer (ECO) who will monitor contractor compliance with the provisions of the EMP on behalf of the DEA as required. The ECO will have the authority to stop the work of any contractor or service provider found in violating the proscriptions of the EMP. The ECO will compile regular performance reports, which may include corrective actions, for project management and DEA. In addition, the Project Company will be required to confirm each CSP plant’s compliance with the EMP and DEA Authorization requirements as part of its annual environment and social reporting to IFC.
PS2: Labor and Working Conditions
IFC’s review considered Project construction and operations with regard to fair, safe and healthy working conditions.
Construction activities associated with each CSP plant will generate short-term employment for up to 800 people during the projected two year construction period. The Company estimates that 30% of this labor requirement will be for unskilled labor and, thus, can be recruited from communities surrounding the project sites if adequate labor resources exist. Each CSP plant’s operations are expected to directly employ 35 people as O&M Company staff on a permanent basis. Additional persons will be employed as subcontractors to the O&M Company. IFC will require the Project Company to require its EPC contractor(s) to prepare and implement a site specific Occupational Health and Safety plan for the construction phase of each CSP plant. IFC will also require each Company to develop a Human Resources Policy and management system consistent with South African labor laws and the requirements of Performance Standard 2 for its operational personnel. At a minimum, each employee must have a contract and understand his/her rights related to hours of work, wages, overtime, compensation and benefits on commencement of employment and when any material change to that employment occurs. In addition, either together or separate from the HR policy, the Companies must declare a commitment against the use of forced labor or harmful child labor, and must not seek to influence or prevent any workers from organizing or seeking collective bargaining rights. The HR policy must reflect a commitment to make employment decisions based on inherent job requirements, non-discrimination and equal opportunity. In addition, the Project Company will need to establish a grievance redress mechanism and disseminate information on how workers’ take advantage of that mechanism among the project workforce.
PS3: Pollution Prevention and Abatement
IFC’s review considered the Project’s management of resource use and waste disposal on the surrounding human and natural environment in its operations.
Water Resources: The area of South Africa’s Northern Cape Province considered most suitable for CSP is a vast, arid and sparsely populated scrub land (2.2 persons per km2) that supports low density cattle farming and one of the major table grape growing industries in the world. That industry is dependent on irrigation from the Orange River, South Africa’s largest, and most controlled watercourse. The Orange River is estimated to have a surplus of 44 million m3/year after abstraction of water to meet existing demand for irrigation and municipal services. The national Directorate of Water Resource Planning has accounted for the use of a portion of this surplus for alternative energy technologies. The operation of the two CSP plants combined is estimated to require approximately 1 million m3/year for steam generation, mirror cleaning and human consumption. The cumulative requirements of the Orange River for farming, alternative energy, urban growth, ecological services and downstream riparians (i.e., Namibia) are currently being studied by the international Orange Sengu River Commission (ORASECOM) but the combined requirements of the proposed CSP plants are not considered significant in the near to mid-term. The Orange River is an International Waterway and, as such, IFC will inform the Government of Namibia of its intent to finance the CSP plants.
Water and Wastewater Management: Water requirements for the operation of the !KaXu power plant are below international CSP benchmarks as a dry hybrid cooling process will be used. The project will withdraw water via electric pump from an established abstraction site on the Orange River approximately 30 kms from the KaXu site. Water will be pumped through a sand filter to a retention/settlement pond and on to a storage pond located on the project site. The water pipeline will be buried along the alignment of an existing access road to the abstraction point maintained by an established grape farm. Both reservoirs will be equipped with floating lids to reduce evaporation.
To reduce overall water consumption, service water will first be used as makeup to the hybrid cooling tower and circulating water system. Water conditioning chemicals may be fed into the makeup water to minimize corrosion and to inhibit mineral scaling. Blow down from the circulation water will be continually treated by lime-softening clarification and filtration processes and then delivered to a clear well where the water will be treated by reverse osmosis before being used for other plant requirements. A blow down pond constructed on the project site will receive wastewater from the power generation process. The brine that will accumulate in this pond through evaporation will be removed at project decommissioning by a DEA-licensed waste management company for disposal at an appropriate waste site. The blow down pond will be lined with an impervious membrane.
Water requirements for the operation of the Khi Tower plant will also be below international CSP benchmarks, given that an air cooling system will be used. The project will withdraw water from the Orange River at a greenfield abstraction point located 10 km from the Khi Tower site. The pumping, filtration and storage facilities identical to the KaXu operation will be employed in the Khi Tower project, albeit with smaller settlement and storage and blow down reservoirs.
Both CSP plants are designed with zero-liquid discharge systems to treat all aqueous effluents according to their level of origin and contamination. These systems will consist of treatment for sanitary waste, oily water waste and process waste water. The sanitary waste water plant equipped with standard treatment features – biological treatment, solids removal, carbon removal, disinfection and sludge drying – will treat effluent from potable and service water usage. Effluent from both the sanitary waste system and the oily water separator system will be fed to a homogenization tank and then to evaporation ponds. Maintenance staff will use de-ionized water for bi-weekly cleaning of mirrors using high-pressure spray washers. Run-off from this process will evaporate or otherwise dissipate into the ground.
Solid Waste and Hazardous Materials Management: Waste generated by both CSP plants will be limited to solid waste construction materials, spent vehicle and construction machinery lubricants and other chemical wastes (adhesives, abrasives, paints and solvents) used in the assembly and maintenance of power plant components. The EMP contains specific provisions for the transport, storage, handling, use and disposal of lubricants and chemicals as well as to contain and respond to leaks, spills, or other emergency situations (see PS4 discussion below). The Heat Transfer Fluid used in parabolic trough plants is a petrochemical and must be managed as a hazardous material. The molten salts used to store heat in CSP plants are not hazardous materials.
GHG Emissions: Carbon emissions associated with the CSP plants will include vehicle operation during construction and operations, and two single 2 MVA diesel generator used to supply construction power to the !Khi and the !KaXu site. The operations of the combined projects represent a reduction in carbon emissions generated by coal or other non-renewable source amounting to approximately 500 Million tons per year.
PS4: Community Health, Safety and Security
IFC’s review considered the Project Companies’ capacity with regard to the management of the impacts of the operation of its facilities on the health, safety and security of surrounding communities.
The EIA studies considered increased vehicular traffic, noise, visual and tourism impacts of each project. In the absence of human settlement within a wide radius surrounding each project site, impacts from construction traffic, noise or visual alteration of the landscape during construction or operations will be negligible. Neither of the Project sites is in any proximity to landscape features that attract tourism to the area (e.g., the Augrabies Falls National Park); and the studies have speculated that the power plants themselves will become tourist attractions.
The EMPs for both CSP plants include provision for the management of vehicular movements (via routings, hours of operations and speed controls) to ensure safe operation on local roads and to minimize noise, dust and road damage caused by construction vehicles. The EMPs make additional provisions that include: avoidance of damage to farm infrastructure (fences, gates, livestock crossings and stock theft); impacts on family structures and social networks from an influx of construction workers; maintenance of disciplined conduct of on-site contractors and workers; and implementation of safeguards to avoid, minimize and control veld fires. IFC will require the Project Companies to develop and implement an HIV-AIDS awareness and prevention program for all construction contractors and staff.
Security Forces and Community Safety: No site security arrangements have yet been developed. IFC will require the Project Companies to develop a comprehensive security protocol for its direct employees or security contractor(s) consistent with the requirements of Performance Standard 4. The Companies will also be required to develop site-specific Emergency Preparedness and Response Plans for each project in coordination with the local administrative authorities and Upington municipal authorities to respond to leaks, spills and other emergency situations.
PS6: Biodiversity Conservation and Sustainable Management of Living Natural Resources
IFC’s review considered the impacts of the construction and operation of the !KaXu Solar One and !Khi Solar One CSP plants on the terrestrial and aquatic ecology of the habitats affected by project infrastructure.
Biodiversity: The EIA for each power plant includes a comprehensive ecological assessment of the two Project sites to determine the impacts of the major infrastructure components of the CSP plants – access road; the solar array (mirror field), power block and related structures, overhead power transmission line; and water pipeline and associated infrastructure – on the habitat and ecological processes. The assessment identified the potential impacts to the following receptors: i) indigenous natural vegetation; ii) threatened plants; iii) protected tree species; threatened animals; and iv) wetlands. The assessments also considered change in surface water runoff and drainage patterns and the establishment of invasive plant species to be potential adverse impacts of the power plants.
The Project sites are situated on rangeland that has been used for commercial stock rearing for nearly 100 years resulting in degradation of natural vegetation. As part of the ecological assessment of the project areas, a sensitivity assessment was undertaken by a specialist to identify areas of high conservation value or that may be sensitive to disturbance.
The consensus of the EIA studies for each power plant is that there will be negligible impacts on terrestrial and aquatic fauna, birdlife or flora during both the construction and operation of the projects. The disruption of seasonal streams and rivers, which represent micro-habitats for certain species of plants and animals, can be avoided or mitigated through the selective siting of project infrastructure and the protection of stream flow from construction activities. A small number of protected tree species will also be affected by land clearing for civil works and the Companies will adhere to the requirements of the National Forest Act in mitigating the impact of their removal.
