While all Performance Standards are applicable to this investment, IFCs environmental and social due diligence indicates that the investment will have impacts which must be managed in a manner consistent with the following Performance Standards. If IFCs investment proceeds, IFC will periodically review the the project’s ongoing compliance with the Performance Standards

PS 1 – Assessment and Management of Environmental and Social Risks and Impacts
PS 2 - Labor and working conditions
PS 3 - Resource Efficiency and Pollution Prevention
PS 4 – Community Health, Safety and Security
If IFC’s investment proceeds, IFC will periodically review the the project’s ongoing compliance with the Performance Standards

The Project is an expansion with a 4.5 hectares brown-field footprint. Biodiversity Conservation and Sustainable Management of Living Natural Resources is not applicable to this Project as it is located in a heavy industrial site (modified and degraded habitat) which has an existing fertilizer operation that will be displaced. Indigenous People (IP) is not applicable as the Project is in a heavy industrial area, and furthermore, no IP have been identified as part of the ESIA. Cultural Heritage is not applicable as the area is not identified as archeological sensitive. In order to accommodate the plant expansion, some existing independent industrial activities are separately being relocated by Governmental authorities.

The Project will have limited environmental and social issues such as air quality, noise, waste, workers occupational health and safety, hazardous waste spill. The Project is a Category B investment as the identified E&S impacts from the Project can be managed through existing project design, and/or readily available mitigation measures as defined in the Environmental and Social Management Plan (ESMP) for the Project to be implemented by CIPREL.

IFC's appraisal considered the environmental and social management planning process and documentation for the project and gaps, if any, between these and IFCs requirements. Where necessary, corrective measures, intended to close these gaps within a reasonable period of time, are summarized in the paragraphs that follow and (if applicable) in an agreed Environmental and Social Action Plan (ESAP). Through the implementation of these measures, the project is expected to be designed and operated in accordance with Performance Standards objectives.

The key environmental and social risks/impacts include noise particularly beyond site boundary, ambient air quality pollution, employees’ and third party onsite workers’ health and safety, increased traffic, pre-existing soil and groundwater contamination, potential contamination from hazardous waste handling, fire/explosion, and community health and safety.



CIPREL has a “Plan de Gestion Environmental et Social” which is the ESMP that addresses measures to be undertaken to ensure that the environmental, health and safety and social risks from the Project are addressed in a manner consistent with host country laws and regulations and IFC’s Performance Standards on Social and Environment Sustainability.



In order to comply with the legal requirement of the Republic of Côte d’Ivoire, Article 12 from the Environmental Code (Loi N°96-766 of October 3, 1996; and décret n°96-894 of November 8, 1996), an Environmental and Social Impact Assessment (ESIA) was undertaken for the proposed Project. The ESIA was completed in April 2011 with thereafter further revisions from Lenders; it contains sections on environmental, social, economic impacts and cultural effects that the Project may have on the surrounding communities during both construction and operation.. In compliance with ESIA guidelines, the Project ESIA was publicly disclosed for comments from The National Environmental Agency(ANDE) and other stakeholders and an approval of the ESIA was obtained in April 2013. The ESIA addresses the potential impacts from the Project and outlines proposed mitigation measures which are further detailed in the ESMP.



Organizational Capacity and Management Programs

CIPREL has an Environmental Health and Safety (EHS) Manager and has in place an EHS management system for its current operation which is ISO 9001 version 2008, ISO 14001 version 2004 and OHSAS 18001 version 2007 certified. CIPREL will strengthen its management systems by developing and implementing management programs to address identified risks and impacts from the ESMP. The EHS Manager’s terms of references (ToR) will be expanded to cover oversight of the construction phase of the Project, and social aspects. The ESMP will be the basis of developing the thematic points of the management programs, key E&S issues to be addressed for construction and operation phase as applicable include: (i) compliance with local environmental, health and safety requirements; (ii) solid and liquid waste handling, treatment, storage and disposal; (iii) occupational health and safety practices and training for employees and third party workers; (iv) labor and working conditions; (v) air emissions (point source and ambient air quality); (vi) noise within and outside site boundary; (vii) emergency preparedness and response; (viii) drainage and storm water runoff; (ix) hazardous material handling and storage; (x) soil contamination; (xi) traffic safety (onsite and offsite); (xii) equipment maintenance; (xiii)
workers’ accommodation; (xiv) third party workers’ labor and working conditions screening mechanism as well as their access to CIPREL’s grievance mechanism; (xv) auditing of contractors implementation of the construction phase ESMP; (xvi) stakeholder engagement with regards to labor, health/communicable diseases and safety including a grievance mechanism; (xvii) environmental, health, safety and social performance monitoring and internal reporting.



The successful implementation of the management programs during the construction phase will require close collaboration between CIPREL, the EPC contractors, and suppliers. The EPC contractor will have an Environment, Health and Safety (EHS) supervisor on the site. CIPREL’s EHS Manager will liaise with the EPC Contractors’ EHS supervisor or equivalent, and ensure that they adhere to the management programs developed from CIPREL’s construction phase ESMP and approved by CIPREL. The EPC contractor’s EHS site supervisor and CIPREL’s EHS team will ensure proper training of employees, contractors and subcontractors, implementation of occupational health and safety (“OHS”) standards on the construction site, have joint meetings on OHS and share lessons learned, and jointly investigate any incidents/accidents related to the Project.



Emergency Preparedness and Response

Storage, handling and use of hazardous material such as Heavy Vacuum oil (“HVO”), Diesel Distillate Oil (“ DDO”) at the facility, the presence of gas, and the presence of a high concentration of industrial activities can present potential hazard in relation to accidental spills/leak, fire and explosion. The specification for the proposed fire-fighting system is extensive and appropriate for an installation of this type. The fire protection equipment to be installed is within normal design parameters for a steam turbine installation, and can be considered satisfactory.



Both the EPC contractor and the Company will develop an emergency preparedness and response plan for the construction and operational phases respectively. The Plan should describe the procedures to follow when handling an emergency situation such as fire, explosion, hazardous material or waste spills, injuries, and natural disasters. This will include establishment of a communication network between the EPC contractor, CIPREL and emergency services such as fire departments, traffic police, the Port Authorities, local medical services, and the companies in the vicinity. Furthermore, the system will be tested through a mock drill to confirm effectiveness of the system or rectify any identified oversight.



Monitoring and Reporting

CIPREL has in place an environmental, health and safety monitoring program which includes periodic monitoring of solid and liquid waste generated (liquid effluent analysis include parameters such as biological oxygen demand, chemical oxygen demand, suspended solid, oil etc), air emissions (CO2 and NOx), noise, energy and water consumptio
n. CIPREL will strengthen its current monitoring program to include indicators established in its ESMP. These indicators monitored during construction include: vehicles accidents, employees health and safety statistics such as near misses, accidents, lost time incident, and job creation within local communities. During operation, monitoring will include: point source emissions and ambient air quality, noise, OHS, quality of effluent discharge, water and energy consumption, greenhouse gas emissions, job creation within the local communities, and livelihood restoration of affected companies. Specific parameters will be allocated to each of the activities above in order to track, monitor, analyze EHS and Social performance and ensure compliance with Ivorian laws and IFC Performance Standards.

Human Resources (HR) Policy

CIPREL currently has sixty (60) employees and this will increase to one hundred (100) once the Project is in operation. During construction phase, up to 1,400 daily workers are expected of which over 90% will be recruited locally. Furthermore, subcontractors will also be used as suppliers of sand and gravel, cement, fuel etc. CIPREL’s HR policies and procedures meet the Ivorian Labor laws and generally meet this Performance Standard requirement. Prior to employment, potential candidates must present an identification card or birth certificate and undergo a medical visit. Each new employee including temporary workers sign a work contract which includes job description, wages, and work hours. Employment benefits are above national requirements. Example of benefits include: supplemental insurance, supplemental pension plan scheme including financial management advise, transportation allowance or transport using company buses, subsidized canteen, access to loans, solidarity fund, allowances for funeral and birth of a child. These policies and benefits will also be applicable to CIPREL staff hired for the Project.



Non-Discrimination, Equal Opportunities and Protection of the Workforce

CIPREL has a written non discrimination policy and applies the principles of non-discrimination and equal opportunity, which is reflected in the diverse workforce. As per national law, CIPREL does not have employees under the ages of 18 hence there is no child labor. Prior to being hired candidates have to provide an identification card or birth certificate, medical certificate, and a copy of his/her judicial standing. CIPREL will use commercially reasonable efforts to contractually stipulate that its suppliers and subcontractors comply with national labor laws, pay employees at a minimum the legal requirements.



CIPREL has a salary grid which is internally accessible, performance evaluation system, and talent reviews process to increase transparency in compensation and promotion.



Freedom of Association and Grievance Mechanism

CIPREL has workers’ representatives that serve as liaisons between management and staff. The workers have freedom of association and the workers’ representatives also liaise with the national labor union. Grievance mechanism appears to be well functioning and is mostly channeled through the workers’ representatives.



Occupational Health and Safety

CIPREL’s occupational health and safety standards are based on OHSAS 18001 which establishes and maintains consistent safety procedures and global methodologies for managing and minimizing safety risks.



All employees are expected to adhere to all OHS related programs and requirements adopted by CIPREL, and as such continued training on EHS will take place. Personal protective equipments such as steel toe boots, uniforms, hard hats, goggles, ear plugs etc are provided to staff as relevant to their job profile. All contractors and subcontractors engaged b
y CIPREL will be required to provide an ESMP prior to commencement of work and expected to adhere to the same safety standards as CIPREL. As such it will ensure that contractors/subcontractors provide their workers with necessary personal protective equipment to carry out work in a safe manner; and in the case of subcontractors, additionally report on onsite health and safety incidents and corrective measures. CIPREL has included in its ESMP a procedure to audit contractors with respect to the above mentioned matters; a similar procedure for suppliers will be developed. Drivers will be required to take a defensive driving course, and be subject to random alcohol and drug testing. A small health clinic and a first aid kits are available on site.



CIPREL has recorded zero incidents, lost time injury, and fatalities in the last 3 years. All work related accidents are reported to the National Security Office (CNPS). Procedures are in place to record and investigate incidents.



Fire and life safety equipment such as extinguishers and water hoses are available onsite and are verified annually by a government licensed third party contractor. The current CIPREL plant has evacuation plan and dedicated fire wardens. A number of employees are trained in first aid and first response. Third party fire and life safety audit have been conducted by the fire department.



As per legal requirements in most western African countries, CIPREL has in place a health and safety committee.. The committee comprises of representatives of the management team, the workers’ representative, staff, and medical doctor. The health and safety committees have legally defined ToR which includes management of employees’ health and safety (including fire and life safety) matters, quarterly meetings and recording and dissemination of meeting minutes.

The steam turbine will convert the existing gas turbine number (GT9) and the new gas turbine (GT10) to a combined cycle operation, including Heat Recovery Steam Generators for both GT9 and GT10 enhancing the efficiency of the power plant by generating 25.5% more power without the use of any additional gas.



GT9 and GT10 will be retrofitted with DLN burners during their scheduled maintenance (mid 2015 and mid 2016 respectively) to further reduce NOx emissions. The backup fuel will switch from HVO to DDO for compatibility reasons once the DLN burners are installed. Use of DDO and retrofitting of the DLN burners will reduce NOx emission to 15ppm (lower than WBG max limit of 25ppm) when using gas and to 74ppm (WBG max limit) when using DDO. It is anticipated that the point source NOx emission monitoring will be on a continuous basis. If continuous monitoring will not be adopted, the ESMP indicates that point source emissions monitoring be conducted on an annual basis.



Limited ambient air quality modeling using air emission model CALPUFF (version 5.8 adopted and recommended by US EPA since 2007) and assuming stack heights of 60m, gas as the main fuel and HVO as back up fuel indicates compliance with ambient quality standards. Further rounds of air modeling using actual baseline sampling data, incorporating use of DDO and DLN burners, assuming the Heat Recovery Steam Generators will be built with 60m high stacks to provide good exhaust dispersal, GT9 and GT 10 with a 40m stack height to verify the impact on ambient air quality. For the first two years of operation, CIPREL will conduct ambient air quality sampling and analyis on a quarterly basis, thereafter, seasonal ambient air quality monitoring will be undertaken every two years.



During construction water will be supplied to the Project through the municipal water networks. No use of boreholes is anticipated. The Project will require approximately12 m3/h, of which10 m3/h will be for the production of demineralised water and the rest for domestic use. Discharges are estimated at 9 m3/h.



Soil and groundwater contamination with petroleum hydrocarbon exists within the Project site however the source was not conclusively determined. Potential sources could be from the previous usages of the Project site which included storage of petroleum hydrocarbon tanks, chemical fertilizers operation; alternative sources could include a number of the neighboring companies involved in petrochemical treatment and storage. Under the concession agreement the liability of such contamination rest with the GoCI. The ESIA indicates that groundwater is shallow and estimated between 0.1 and 4.8m; the level is regulated by the Ebrié lagoon which is known to be polluted by both sanitary and industrial waste. The ESMP indicate that soil excavation will be kept to the minimum in order to avoid spread of contamination. Contaminated soil will be confined on site in a lined area, and covered during rainy season. C
IPREL plans to reuse this soil in deep fill noting that any excess soil contamination will be disposed through a licensed contractor in a licensed facility.



The construction phase will have some impact on ambient noise mainly due to use of heavy equipment and influx of traffic on site. The Project is located in an industrial zone, the closest residential area, called "Vridi-Channel SIR" with an estimated population of 25,720 people is located 2 km away. However, there are also four CIE employees’ residential properties for employees on call right across from the existing plant which are sensitive receptors. Mitigation measured that will be implemented include the use of construction equipment fitted with system noise limitation where possible, restricting noisy works to daytime, enforcement of vehicle maintenance schedule, temporary noise barrier if the noise generated by construction activity is greater than 85 dB. During operation the addition of the combined cycle, the fans of the air cooled condensers will increase noise levels within the plant and outside plant boundary. Noise barriers will be put around the loud equipments such as steam turbine. Monthly noise monitoring will be conducted during construction and on a quarterly basis during operation. Additional mitigation measures such as further noise barriers or double glazed windows in CIE employees’ residential properties across from the site will be implemented as necessary.

The increase of workers during the construction phase will require availability of mobile toilets. CIPREL will ensure that sanitary waste generated during the construction phase is adequately disposed of. The addition of staff for the Project will also require additional sanitary facilities to be built. Sanitary waste will be stored in septic tanks that are pumped by third party licensed contractor as needed. Effluent discharge from operation will go through an oil and water separator and decanter prior to being treated in a chemical neutralization pit built for the Project. As indicated in the ESMP, effluent monitoring of parameters such as temperature, pH, total suspended solids, BOD, COD, hydrocarbons, lead and cadmium will be on a continuous basis. Storm water drainage system around areas where potential contamination could happen such as hydrocarbons storage areas will go through an oil and water separator and then discharge to the lagoon after visual verification of non contamination.



Waste generated during construction will include excavated soil, domestic waste, various packaging, containers, waste oil, batteries etc. CIPREL currently has an adequate waste management system with includes separation, recycling, confined storage, and disposal through licensed contractors. A chain of custody documentation to final destination is provided; in the case of hazardous waste, a certificate is provided from the governmental agency in charge of classified installation (SDIIC) to confirm that the waste was col
lected and disposed off in an approved manner. The same waste management procedures will be applicable to the Project.



CIPREL’s current facility has adequate material storage practices providing sufficient secondary containment for liquid materials. Such practices will also extend to the Project as described in the ESMP.



Greenhouse Gases are estimated for the whole of CIPREL’s operation (existing plant and the Project) is 2.414 million tCO2 per year with an anticipated annual reduction of 180,000 tCO2.

As indicated above, the site is in an industrial area surrounded with heavy industries, the CIE employees’ residential properties; the nearest official residential area is located 2 km away. Given the concentration of heavy industries around the Project, a potential accident can emanate from CIPREL or any given companies around it. To further contain potential accident within its compound CIPREL has built reinforced concrete walls in part of the site as recommended by a hazard analysis that was conducted. A similar wall will need to be built for the Project. To minimize health, safety and security impacts, CIPREL will develop management programs to control the safety of delivery of material; entry to the site from the main road; road side incident management and spill response; and defensive driving and random alcohol and drugs testing for truck drivers.



CIPREL will also ensure that security personnel have undertaken necessary screening and training in accordance with good industry practices. CIPREL will report to public authorities any credible allegations of unlawful or abusive acts of security personnel.

During the ESIA and abbreviated RAP process, a range of stakeholders that may be interested in the Project was identified within the project area of influence. This identification was followed by stakeholder engagement to inform and raise Project awareness, answer questions and record suggestions and concerns of the following: (i) the port authorities and relevant administrative authorities; (ii) active companies; (iii) people engaged in informal commercial activities. Several meetings took place and the process is fully documented in the ESIA. This engagement process was appreciated by the stakeholders. The main conclusions of this engagement process are:
the Project is welcomed both for job creation and increase supply of energy given the increase in demand both locally and in bordering countries; and
suggestion that CIPREL take the necessary measures with regards to environment, health and safety to mitigate impacts related to the Project and particularly take into account the sensitivity of/additional risks to the surrounding companies activities.
Generally, there are no anticipated significant adverse impacts to the community resulting from the proposed Project. As indicated in the ESMP a community grievance mechanism will be put in place for both constructions an operation phase. No further grievances have been received to date, but this could also be due to lack of awareness of the grievance procedures. CIPREL will put in place an effective grievance mechanism that will be communicated to relevant stakeholders. In addition, CIPREL will put in place indicators to test the effective of the grievance mechanism.

For further information on the Project please contact:
CIPREL SA
Rue des Textiles, Zone Industrielle de VRIDI
Commune de Port Boüet
01 BP 4039 Abidjan 01, Côte d’Ivoire

Contact: Xavier Horiot
Email: mailto:xhoriot@ciprel.ci

or
Agence Nationale de l’Environnement (ANDE)
Riviera Attoban en face du Groupe Scolaire Jules Ferry
08 BP 09 Abidjan 08
Côte d’Ivoire

Broad Community Support is not applicable for this project

Current client performance is aligned with applicable Performance Standards and EHS Guideline requirements. No ESAP is required.