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.

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.

PS5 Land Acquisition and Involuntary Resettlement is not applicable since the proposed project will not require any land acquisition or resettlement.

PS6 Biodiversity Conservation and Sustainable Natural Resource Management is not applicable since the project is not located in sensitive modified or critical habitats and will not affect ecosystem services.

PS7 Indigenous People does not apply since there are no communities in the Project area that would be considered as ‘Indigenous’ as defined by the World Bank Group.

PS8 – Cultural Heritage does not apply as there are no known archaeological or historic sites within the project site’s boundaries.

The proposed investment is a Category B project because the potentially limited environmental and social impacts that may result from operating the project can be avoided or mitigated by adhering to generally recognized good practices.
The Company has presented information and plans that will seek to address environmental and social risks and impacts in accordance with the Ghanaian laws and regulations, the IFC Performance Standards on Social and Environment Sustainability, the applicable elements of the World Bank Group (WBG) General EHS Guidelines, and the attached Environmental and Social Action Plan (ESAP.)

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.

Environmental and Social (E&S) Assessment

For purposes of assessing the impacts of the project, the Company either hires qualified environmental consultants or to conduct internal assessments to determine the level of risk of its operations. The process and documents established and reviewed indicate that the Company has assessed the risks operations and implemented necessary measures. Additional aspects needed to operate the project in accordance with the IFC PSs are reflected in the ESAP, part of this summary.



Environment, Health, Safety (EHS), and Social Management Program and Organization

The Company’s management is committed to adopting and implementing an Environmental, Social, Health, and Safety Management System (ESHS-MS) for the project based on the Ghanaian regulations; IFC’s Performance Standards; and relevant WBG EHS Guidelines. The ESHS-MS includes; (a) procedures for identifying social and environmental risks and impacts; (b) development and implementation of environmental and social management plans (ESMP); (c) monitoring and internal audits; and (d) ensuring adequate employees ESHS training. In addition, to ensure sound EHS practices related to the fuel distribution/retailing conducted by their costumers, the Company has developed procedures including contractual clauses about EHS compliance, use of personnel protective equipment, work permits, report of incidents/accidents, compliance with local labor laws, etc. In addition, the Company has procedures in place (i.e., contractual clauses in contracts between company and contractors, periodic audits, job safety analysis, etc.) to ensure contractors comply with the applicable environmental, health, and safety requirements.



The Company has dedicated qualified personnel to handle the EHS aspects of its operations. It has a Safety, Health, Environment and Security (SHE & S) Manager supported by a Safety Officer, an Environmental Officer, and a Security Supervisor. As needed, the Company also hires environmental consultants to conduct studies, monitoring, audits, etc.



Training, monitoring, and reporting

Chase periodically conducts EHS training for all its own employees and contractors on aspects such as safety audits, job related risks, hazardous materials, fire prevention, proper use and disposal of residues and products, etc.



The Company has a monitoring program to assess the EHS performance of its operations including ambient noise, water quality in the nearby Gao Lagoon including oil and grease, total suspended solids, BOD, COD, and VOC, soil quality in the tank farm , number of accidents/incidents, etc. In addition, as indicated in the ESAP, the Company will develop and implement a soil and under groundwater monitoring protocol to ascertain there is no contamination as result of its operations.



The Company will submit annual environmental and social performance reports to local regulators, lenders and investors.



The terminal has fire prevention rule
s and emergency preparedness and response plans. It has a foam firefighting system, water sprinkler/cooling system, and fire water storage onsite with high pressure water pumps, which can be powered by onsite diesel generators in case of power failure. The fire prevention and firefighting system complies with the internationally accepted American National Fire Association (NFPA) fire prevention requirements.

Human Resources Policy and Management

Chase has developed Human Resources (HR) Policy and Procedures including provisions related to non-discrimination and equal opportunity, wages and benefits, no engagement in forced or child labor, grievance mechanism and safe working conditions. There is no child labor or forced labor at the terminal. The minimum working age is 18 years old. The Company employees are not unionized; however, as per its Human Resources Policy the employees have freedom of association. These procedures are appropriately communicated to all employees.



The Company will establish a worker’s grievance mechanism defining the channels available to submit the grievances (i.e., mail, phone, verbal report to immediate supervisor/reporting authority; etc.) The grievance mechanism, which will be part of the HR policy, will be communicated to all employees. The Company will also maintain a database with information regarding grievances outcomes.



The proposed project generates about 70 direct jobs and 150 indirect jobs. The majority of workers are locally hired from the surrounding villages living in existing local housing facilities nearby.



Occupational Health and Safety (H&S)

The handling of the occupational health and safety aspects are part of the Company’s ESHS-MS which includes a zero accident policy. It is Chase Petroleum policy to conduct its business in a manner that protects the safety of employees, others involved in its operations, customers and the public. The company will strive to prevent all accidents, injuries and occupational illnesses through the active participation of every employee. The company is committed to continuous efforts to identify and eliminate or manage safety risks associated with its activities. The records until now indicate the company has not had any accident. Key safety measures include: ear protection when workers noise exposure is 85 dB (A) or more, equipment enclosures and buffers wherever noise levels are above 90 dB (A), preventive equipment maintenance, etc. The Company also focuses on the prevention of risks related to work at height, work in contained spaces, work with live power lines and equipment, fire, exposure to chemicals, exposure to electromagnetic fields, etc. The Company makes compulsory the use of personal protective equipment (PPE.) The employees undergo periodic medical assessments to identify potential work health related conditions.

The design of the project is based on established state-of-art practices and technologies.



The operational phase requires water for fire prevention, and for domestic use. The terminal does not generate effluents with the exception of domestic wastes. To handle storm water Chase has installed a storm water management system around the project site which includes a segregation system for contaminated (oils) versus uncontaminated storm water. Prior to discharge to the nearby Gao lagoon, the contaminated wastewater passes through an API oil-water separator and is monitored to assess the oil and grease concentration levels thus ensuring the wastewater complies with the applicable local and WBG EHS Guidelines, and IFC PSs. The domestic wastewater is handled through on-site septic tanks.



The main emission sources include VOCs from fuels storage/loading/unloading, leaks from pipe and pumps seals, etc.; and SO2 and NOX from the driving of the bulk road vehicles. To prevent the releases to the atmosphere, Chase stores gasoline and products with similar or higher vapor pressures in floating roof tanks with primary seals to minimize vapor emissions, periodically inspects the floating roofs, and load trucks by submerged methods. It also has periodic maintenance of equipment to prevent the likelihood of potential leaks.



Electricity is sourced from the power grid and the Terminal has a backup generator to compensate for the frequent power outrages. The water needs for operation and consumption are satisfied by the Ghana Water Company. Water and energy consumption are monitored and controlled.



Noise generation is not a major aspect of the terminal operations. However, ambient noise level at the pump house is monitored periodically. To minimize the impact of bulk road vehicle traffic, fuel transfers are carried out during daytime hours and the vehicles are required to be mechanically sound prior to entering the project premises.



The domestic waste generated is collected by Zoomlion Company Limited, a registered waste management company in Ghana. The hazardous wastes (oil-water separator sludge) is collected and stabilized with lime as authorised by local environmental authorities and the skimmed oil collected from the oil-water separator is pumped back into the tanks and sold as gasoline. The Company does not use PCB’s in transformers, ozone depleting substances, or banned/phased out substances.



Given the potential for fuel leaks and spills, Chase has developed preventive measures such as periodically testing the storage tanks to detect potential leaks, ensuring that delivery hose connections are properly placed during loading of tanks and bulk road vehicles, placing drip trays and containers under pipes and connections with potential of small spills and leakage, etc. In addition, all storage tanks have a containment bund which is linked to the API oil water separator.



The oil tankers are required to comply with all a
pplicable environmental standards of International Maritime Organization (IMO). The characteristics of the oil tankers must be certified to the standards by an independent control specialist in the field and approved by the manager of the terminal. Ship vetting and all buoy berth (ABB) operations are the responsibility of Kpone Marine Services Limited. There are also routine inspections for spill/fire prevention at each jetty during unloading periods, including pipe connections, water pump readiness, fire source inspection, etc. Jetty operations and it associated pipeline inspections fall under the responsibility of Tema Oil Refinery.



Guided by the oil spill risk assessment plan prepared, Chase conducts periodic mechanical integrity checks and pressure testing of all systems and tank trucks are subject to safety audits prior their entrance to the terminal; periodically monitors all pipe valves and flanges; the areas where solvents for cleaning and degreasing are used are paved to prevent the likelihood of soil contamination; etc. In addition, Chase also developed and is implementing; (a) an Oil Spill Prevention Plan which involves a regular maintenance schedule for all equipment and machinery involved in the crude oil storage tank farm operations, and; (b) an Oil Spill Contingency Plan outlining procedures, needed equipment, and steps to be taken in the event of probable or actual oil spill (i.e., product overflow from storage tanks, overflow from drain sumps, leakage of storage tanks, spills from pipeline bursts or leaks, oil spills from products transfer, leakage of products from tanker trucks, etc.)

The Company has also developed rigorous safety procedures which include periodic maintenance of the equipment and systems (i.e., tank corrosion prevention, secondary containment bunds, pipelines, fire systems, etc.), confirming that trucks are earthed before transfer pumps are turned on, establishing designated routes for trucks leaving the premises, etc. In addition, the Company has also developed a traffic management plan to address the issues relevant to the 150 truck capacity of the terminal.



To prevent fire outbreaks, the Company developed fire risk assessment and prevention plans which include conducting periodic fire drills, periodic integrity checks and testing of fire fighting systems and the development of an emergency response plan to prevent, prepare for, respond to and recover from all possible emergencies affecting or threatening the project including explosions, fire, leaks and spillages. The site has dedicated personnel to handle on-site accidents and the Company conducts annual emergency response training/refreshers which include periodic emergency drills.



Products are sold ex-depot and the custody transfer from Chase Petroleum Ghana Ltd to Oil Marketing Companies ends within the depot after acceptance of measurements. Transportation of the products to the various distribution centers is the responsibility of th
e Oil Marketing Companies who can outsource the transportation or do it directly with their own fleet.



There is no manufacturing process in this project. The project does not generate any potential anticipated indirect GHG emissions since their annual electricity consumption of 300,000 KWH is generated from a government operated hydroelectric power plant.



As part of the project, the Company will increase its capacity by installing additional storage capacity inside the current project site. Once the design details are completed and the potential EHS impacts and mitigations, Chase will submit those prior beginning construction as indicated in the ESAP.

The project is located in a heavy industrial area and the closest community to the project site, Tema, is approximately 7 km distant; thus it has minimum if any direct negative impacts on communities. To prevent negative impacts on the road due to the buyers’ transport of fuel, Chase has established a rigorous safety inspection program to assess the condition of the bulk road vehicles prior entering the terminal including permits check, exhaust spark prevention, brakes, etc., and has also developed a rigorous training program for drivers prior to them commencing with the transport of fuels.



The Oil Marketing Companies which buy and transport Chase products have their own Contractor Safety Requirement which have to be satisfied prior the transportation contracts are awarded



Chase hires only unarmed private security and does not require any support of the Ghanaian public armed forces. The Company will implement security policies and procedures commensurate to the project risks and will conduct training for the private security personnel to ensure appropriate conduct with neighboring communities as indicated in the ESAP.

Chase has also made one of its pillars to develop its corporate social responsibility. As part of the construction and environmental authorization process, it has conducted public consultation. No negative aspects were raised other than the expectation to obtain possible jobs.

Chase will develop a procedure to receive, register, redress, and monitor community grievances. This procedure will be designed to be easily accessible, efficient, and to respond to the grievances in a culturally appropriate way. The Company will decide the most appropriate person to manage those. Copy of the mechanism will be submitted to IFC as per the ESAP.

As part of Chase’s corporate social responsibilities, the Company will continue conducting various events such as establishing a computer laboratory for supporting local elementary and secondary schools in Accra, support about Safe Driving campaigns etc.

Chase will disclose this document in local prevailing language English in Notice Boards located at plot no. aA/73/1Tema and The Elizabeth 69 Senchi Link Airport Residential Area Accra. Please contact the following for enquiries or concerns about the environmental and social impacts of this project.

Name Salim Toure
Company Chase Petroleum Ghana Limited or Chase Petroleum Ghana Limited’s representative
Street Address The Elizabeth 69Senchi Link Airport Residential Area
Village/City Accra
Phone +233-544343295

Broad Community Support is not applicable for this project

Action	Due Date
Develop and submit copy of the Security Protocol to be established	30-Jun-13
Develop and submit copy of the Workers Grievance Mechanism	30-Jun-13
Copy of the protocol to monitor soil and underground water conditions to ascertain there is no contamination resulting from the company operations	30-Jun-13
Copy of the environmental , health, and safety impacts/mitigations assessment related to the additional storage tanks to be built	30-Jun-13
Develop and submit copy of the Community Grievance Mechanism	30-Jun-13