Key E&S impacts potentially associated with this project include air emissions, environmental noise, construction related E&S impacts, land and marine biodiversity, GHG emissions, impacts to fishers, land acquisition, security management, labor and community related impacts and health and safety risks during construction and operation. The proposed project is Category A per IFC’s Environmental and Social Sustainability Policy.                                                  

 Environmental & Social Assessment and Management System

EDP is in the process of developing a comprehensive environmental, occupational health, safety and social management system (ESMS) with the aim of integrating E&S management and responsibilities in all the activities conducted in construction and operations. The ESMS is being developed with the support of a consultant firm (ERM). The ESMS will set the framework, policies, directives, management programs, and operating procedures to support the E&S management of the company and pursue continuous improvement. The ESMS is being designed to comply with Salvadoran regulations and will be aligned with international management standards ISO 14001, OHSAS 18001, and IFC Performance Standards. 

EDP’s draft ESMS manual indicates that the management system will be composed of 14 directives or elements that will cover the requirements set forth in IFC PS1. All the commitments and requirements of the ESIAs environmental management plan will be included in the management programs of the ESMS.  As per ESAP items # 1 and # 2, EDP will ensure that the ESMS for construction and for operations, including EDP’s Environmental, Social, Health and Safety (ESHS) policies, are aligned with IFC Performance Standards.

Policy

EDP has recently issued the company’s ESHS policy, the human resources policy and the security policy.  The ESHS policy presents the company’s overarching declaration of their environmental and social objectives and principles that will direct their activities. The policy is applicable to all activities, assets, employees and contractors. It reflects EDP’s approach towards sustainability and to the proactive management of environmental and social risks and impacts. It includes specific objectives in regard to environmental and social performance, and aims for continuous improvement, effectively fulfilling the requirements for policy statement under PS1. The dissemination of the policies among employees, contractors and subcontractors is part of the ESMS rollout process described in ESAP items # 1 and # 2.

Identification of Risks and Impacts

Two separate ESIAs have been prepared for the project by international and local consultants, including: (i) the ESIA for the power plant and the marine terminal (“LNG to Power”) prepared by Dillon Consulting from Canada, in association with EcoIngenieros from El Salvador in 2014, and amended in 2016 and 2018; and (ii) the ESIA for the transmission line (“Proyecto Línea de Transmisión Ahuachapán a Acajutla”) prepared by ERM and Roberto Escalante Capital Natural in 2016.

The power plant and marine terminal ESIA identified environmental impacts to native vegetation, terrestrial and marine fauna, air, soil, surface water, groundwater and seawater quality, noise and vibrations, for both the construction and operations phases. The studies identified social related impacts with regards to influx, infrastructure, public services, community health, safety and security, economic activities such as fishing, and cultural resources, as well as positive impacts including improvement to local employment and other economic activities and the increase in energy supply. 

The ESIAs also includes an initial cumulative impact assessment of E&S risks and impacts from other existing, planned or reasonable defined developments in the area. The study recognizes that the project could have a cumulative impact on the airshed because of two neighboring power plants operated by other companies, but offers evidence that an adverse cumulative impact will not occur. The T-Line ESIA identifies and evaluates impacts to the physical, biological and socioeconomic environment, including public expectations, restrictions to land use, displacement and disturbance of archeological sites, as well as social risks and road safety risks for the community. The T-Line ESIA identifies positive impacts as well, including the generation of jobs and improvement of the local economy. Both ESIAs include thorough analyses and assessment of social impacts, and defines comprehensive baselines of the preexisting conditions in communities in the direct and indirect area of influence.

The social baseline of the two ESIAs did not identify or record any indigenous community or indigenous land or resources being affected by the project (including the T-Line).  The National Department of Indigenous Peoples and Cultural Diversity of the Secretary of Culture (SECULTURA) indicates that less than 1% of the population of the departments of Sonsonate and Ahuachapán are Indigenous Peoples.

Cultural heritage surveys consistent with Salvadoran legislation and PS8 requirements were undertaken for the power plant and T-Line ESIAs.  The historical sites at the port of Acajutla will not be affected. Surveys along the T-Line found a total of 13 sites with archaeological resources. The selected ROW route avoids all these archaeological sites and does not affect any historical resources. All the archaeological permits for the project have been granted by local authorities. Cultural heritage chance finds procedures will be managed through EDP’s E&S management system indicated in ESAP item # 1 and # 2.

The ESIAs adequately cover Salvadoran regulations and are generally aligned with IFC requirements. However, there were some areas that needed improvement.  These were proactively addressed by EDP with the following supplemental E&S studies conducted from February through April 2018: (i) additional marine biodiversity studies for fish, marine mammals and sea turtles, covering aspects such as: whales migratory patterns, turtles nesting activity, location and conditions of corals and oyster beds, and documenting the critical habitat assessment around the marine facility; (ii) avifauna study for the Acajutla-Ahuachapán T-Line to document birds taxonomic classification, identify residence status of avifauna and perform a risk-based determination of important sites along the ROW; (iii) Critical Habitat assessment for the Ahuachapán to Acajutla T-Line, following the guidelines and criteria of IFC PS6; (iv) public health baseline with additional and updated health information from the area of influence of the project; and (v) workflow and labor supply review, to identify the project workforce needs and review the potential labor supply from surrounding communities and manage influx.

As indicated in ESAP item # 3, EDP will conduct a Cumulative Impact Assessment (CIA) study aligned with PS 1 requirements considering all relevant Valued Environmental Components (VECs) of the project, including: marine and road traffic, biodiversity, noise, groundwater, influx, and fishers. EDP will incorporate any recommendation from the study in the corresponding ESMS plans and procedures.

With regards to occupational health, safety and process safety, EDP has carried out the following risk assessment studies as part of the front-end engineering design: (i) Hazard identification study, or HAZID, which identified 18 major and worst-case, credible scenarios for the project; (ii) Identification of risks associated with possible simultaneous operations, or SIMOPs, for the marine terminal; (iii) Quantitative risk analysis study, or QRA, to examine the potential risks to the environment and the public as a result of the 18 scenarios identified in the HAZID. 

The company will incorporate the findings of these studies into the final design package of the project, and will include basic safety studies, documents, and activities, as applicable such as: (i) HAZIDs for the marine terminal, regasification and pipeline; (ii) Hazard and operability study, or HAZOP for the LNG and regasification portion of the project; (iii) Layers of protection analysis, or LOPA for the FSRU; (iv) As low as reasonably practicable studies or ALARP, as applicable; and (v) an updated QRA incorporating the results of these studies and other safety scenarios and considerations for the project (i.e. probabilistic explosion risk analysis, analysis of smoke, gas and vapor dispersion, cryogenic spill analysis, ship collision analysis, study of fallen objects; safety transportation study).  ESAP item # 4 details this commitment and requires EDP to incorporate the resulting recommendations not only in design considerations but also into the company’s ESMS with the aim to add controls and safety barriers to adequately manage risks and impacts.

Management Programs 

EDP has identified the management plans and controls required to adequately address project E&S impacts. The addendum of the power plant and marine terminal ESIA outlines the framework for environmental and social management of the project and commits the company to establish an ESMS with policies, plans and procedures to prevent and control the impacts, and to improve or enhance the compatibility of the project with the environment and surrounding communities.

As part of the development of the ESMS, EDP will elaborate and develop all the E&S management plans (ESMPs) outlined in the ESIAs, which will help the company to manage all E&S aspects of the project in a streamlined and consistent way. For each identified environmental and social impact, the ESMPs will present a set of mitigation measures to be adopted for the different phases of the project, performance indicators and monitoring and reporting requirements as well as the implementation timeline and responsible parties. 

In addition to the ESMPs described in the ESIAs, the following management programs will be developed by EDP to manage risks identified in the ESIAs and during the E&S due diligence process, which will be integrated into the ESMS as indicated in ESAP item # 5: (i) stakeholder engagement plan, or SEP; (ii) community grievance mechanism; (iii) local procurement plan; (iv) local hiring plan; (v) labor grievance mechanism; (vi) fishers’ management and livelihood restoration plan; (vii) influx management plan; (viii) workers transportation management plan; (ix) cultural heritage chance find procedure, and (x) marine sediments management and monitoring plan. These ESMPs will be aligned with IFC Performance Standards.

All contractors working on site will follow EDP’s ESMS. The power plant, T-Line, FSRU, mooring system and subsea pipeline will be constructed via separate EPC packages.  It is likely that main EPC contractors will bring their own E&S management systems.  EDP will review the compatibility of their management systems and ensure that there are no gaps between these and EDP’s ESMS, and will develop ESHS bridging documents to facilitate implementation and monitoring.  As required in ESAP item # 6, EDP will conduct a gap analysis between the EPC Contractors’ management systems and EDP’s and will develop an ESHS bridging document, clarifying which ESHS rules and procedures are enforced to bridge the identified gaps and create a seamless process to safely execute the work program.  The bridging documents will ensure that the construction and operation is managed using the highest set of standards available to the main parties and all required obligations are fulfilled to meet local legislation, IFC requirements, company objectives and policies.

The oversight of the contractors will be accomplished through the development of a contractor management and assurance plan (CMAP), as indicated in ESAP item # 7, which will be a key component of EDP’s management system.

Organizational Capacity and Competency

The in-country director of EDP is currently overseeing all aspects of the project, supported by the appointed project manager from Invenergy and a team of engineers and lawyers.  Environmental and social consultants developing the ESIAs have been also supporting all aspects of environmental permitting and stakeholder engagement. 

EDP proposes an organizational structure within its ESMS manual. The proposed structure is comprised of an ESHS manager with a direct reporting line to the project’s director, and a team in the field of four site coordinators to oversee community relations, health and safety, security and environment correspondingly.  The proposed staffing plan includes necessary ESHS resources in the field to adequately supervise and manage E&S performance in all the components of the project, as well as personnel based in San Salvador to ensure appropriate coordination at the corporate level and with authorities.  ESAP item # 8, requires EDP to hire the personnel proposed in EDP’s E&S staffing plan for the construction phase and to update it for the operations phase allocating sufficient and well-trained resources to manage all ESHS aspects throughout the project life cycle.

Emergency Preparedness and Response

Given that project construction has not started yet, any early works (surveying, topographic works, site reconnaissance activities) is performed mainly by consultants with their own emergency response procedures, and where necessary relying in CEPA’s resources.

During construction, EDP, together with the EPC contractors are required to develop and implement an emergency preparedness and response plan (EPRP) as per ESAP item # 9, and to have qualified personnel and equipment to respond to potential emergencies at their construction areas. The EPRP will also consider any emergency that may impact the public and surrounding environment.  The EPRP will consider the capacity of Salvadoran national and local civil protection systems and will be widely disclosed to ensure potentially affected people are aware of the risks and know how to respond in case of emergencies. 

EDP will also develop an EPRP for operations, as indicated in ESAP item # 10, focusing on the highest risks scenarios for each of the project components, with due consideration of process safety management and industry best practice. The contingency plan for operations phase will include or refer to the design documents and risk assessment studies that describe the measures for mitigating potential emergency events, and corresponding contingency measures for marine traffic safety, LNG regasification process, natural gas storage operations, thermal power plant operation, and electric power transmission. In addition to protection of project facilities, the EPRP will include plans to respond to emergencies that could affect the environment, fishers and neighboring communities. 

Both plans will ensure a thorough process to track and learn from actions and recommendations from drills and incidents, and include adequate communication with stakeholders. EDP will determine ways to integrate these plans within the Acajutla’s port emergency response plan, crews and resources.

Monitoring and Review

EDP will develop all the monitoring plans referenced to in the ESIAs for both the construction and operation phases and perform any additional E&S monitoring requirements derived from the supplemental studies and action items included in the ESAP. The monitoring plans will be part of EDP’s ESMS and will cover aspects such as stack emissions, air quality, liquid effluents, cooling water discharges, noise, groundwater, seawater, workplace conditions, biodiversity, social aspects including security, fishers, stakeholder engagement, worker transportation, affected landowners, water and energy consumption, GHG emissions, marine sediments, benthos, fish, turtles, marine ecosystem, and ballast water. 

EDP’s ESMS manual describes system audits, monitoring and general review processes. The project will track its E&S performance through several mechanisms, including internal inspections and audits and comparison against key performance indicators (KPIs).  Monitoring will also include regular internal ESHS inspections and compliance reviews performed as appropriate by various departments.  The inspections reports, incorporating corrective actions, will be submitted to EDP’s senior management team who will be responsible for implementing all the corrective actions.  EDP will review and evaluate the effectiveness of the ESMPs on a regular basis, in response to changing circumstances as well as internal practices.  As indicated in ESAP item # 11, EDP will develop an E&S assurance plan and implement an action tracking system to record all the findings, observations, lessons learned and opportunities for improvement, monitor corrective and preventive actions to completion, and prevent recurrence.

Social Investment

In accordance with Salvadoran legislation, EDP will annually invest a predetermined amount per MW produced in social development through the central government administered Local Development Social Investment Fund (FISDL).  The FISDL through a non-for-profit organization, the Salvadoran Foundation for Economic and Social Development (FUSADES) will implement social infrastructure projects prioritized by the municipality of Acajutla and selected and overseen by a committee comprised by EDP, FISDL and the municipality. EDP initiated social investment through this model in 2015 and has benefited approximately 3,000 community members with road and electricity distribution projects, among others.                                                    

EDP has currently 19 employees: 11 women and 8 men.  The workforce required during project implementation is anticipated to reach approximately 1,540 direct and third-party contractors at peak construction. For the power plant, the peak workforce will be approximately 1,200 workers, while for the marine terminal and the T-Line peak labor is expected to be approximately 140 and 200 respectively.  It is expected that there will be approximately 100 permanent employees required for operations. Local communities have high expectations on employment opportunities, particularly among residents of the town of Acajutla.  EDP will give priority to recruiting workers locally, but semiskilled and skilled workers are also expected to commute from other areas of the Department of Sonsonate and Ahuachapán and from San Salvador.

Working Conditions and Management of Worker Relationship

Human Resources Policies and Procedures

EDP has developed a human resources policy that is aligned with IFC PS2, and is in the process of developing and implementing associated plans and procedures that will be compliant with Salvadoran labor laws and regulations and will be consistent with IFC requirements.  Per ESAP item # 12, EDP will develop and implement the necessary human resources related procedures appropriate to its size and workforce, and will staff its human resources department accordingly. The procedures will provide the description of working conditions and requirements for staff and contractors, ensuring compliance with EDP’s policies and IFC requirements regarding non-discrimination, equal opportunity, occupational health and safety, freedom of association and collective bargain, and prohibition of child and forced labor. These procedures will be written in such a way as to be easily understood by workers.  Human resources policies will be applicable to and widely disclosed among all direct and indirect workers.

EDP will develop as per ESAP item # 13 a code of conduct that aligns with IFC PS2 and references its anti-discrimination policy, avoidance of child and forced labor, includes policy statements against sexual and workplace harassment, and prioritizing local hiring. The code of conduct will also include specific provisions to manage behaviour of workers within local communities and avoid the incidence of nuisances and negative social and health impacts. Information about the code of conduct will be provided during inductions to all direct and contractors’ workers. In addition, EDP will implement measures to manage the risk of gender-based violence as indicated in ESAP item # 14. These measures will include: a) induction and training program on human resource policies, procedures, code of conduct, and awareness about refraining from unacceptable conduct toward community members, specifically women; b) the grievance mechanism for handling any gender-based violence-related grievances; and c) cooperation of contractors in investigating complaints about gender-based violence.

Working Conditions and Terms of Employment

EDP will provide contracts to all its direct employees on permanent or temporary basis according to the labor requirements and aligned with Salvadoran legislation. Through the CMAP, EDP will ensure that all contractors’ workers are provided with contracts and adequate labor and working conditions. EDP is working with the municipality of Acajutla to maximize the number of local workers available for the project and is expecting to hire all unskilled workers from nearby communities. When semiskilled and skilled workers are not available in Acajutla, EDP will recruit personnel from nearby urban centers such as Sonsonate, Ahuachapán and San Salvador. EDP does not plan to provide workers accommodations.  As indicated in ESAP item # 5, EDP will develop a workers’ transportation plan to ensure that EPC contractors provide adequate and safe transportation from the main supply centers.

Worker’s Organizations

Salvadoran labor law protects collective bargaining and the right to strike as well as defining minimum wage, overtime rates and working hours, worker’s compensation and entitlements. There are a number of labor unions active in the area, such as the Union of Workers of the Electric Sector (SISEL) and the Union of Workers of the Port Industry of El Salvador (STIPES). Representatives of these and other labor unions have participated in stakeholder engagement events organized by the project. EDP will not discourage workers from joining unions or otherwise prevent workers from forming organizations. EDP will disclose information about union agreements and representation during worker inductions. 

Non-Discrimination and Equal Opportunity

EDP will developed a local hiring plan aligned with IFC PS2 (ESAP item # 5), that includes anti-discrimination, forced labor and child labor prohibition clauses. In construction and operations EDP will make use of the “National Network of Employment Opportunities”, an initiative implemented by the Salvadoran Ministry of Labor that integrates public and private institutions to support local employment. Both, the Municipality of Acajutla and the Department of Sonsonate are registered in the program that maps skilled and non-skilled workers available at a local level.  EDP and contractors will submit monthly reports of available positions to the network and EDP’s stakeholder engagement and communication teams will disseminate information about job openings.

The local hiring plan will define and implement strategies to increase hiring from residents of Acajutla, local fishers and from directly affected communities along the T-Line. These strategies will include: (i) communicating job opportunities to different sectors of the local population, including men, women and vulnerable groups; (ii) hiring a staff member to enhance local recruitment; (iii) assisting local residents with the application process including facilitating access to computers and internet; (iv) defining policies prioritizing workers in the directly affected area (fishers, local residents, displaced people); (v) broadly communicating EDP’s local hiring policies; (vi) implement a training program to provide basic skills and enhance the suitability of local population to access project and other industry jobs; and (vii) define measures for monitoring and evaluation of the implementation of the strategies, including assessing workers diversity. 

Retrenchment

As part of the human resources plans and procedures to be developed as per ESAP # 12, EDP will develop a framework for the demobilization of the workforce following completion of the construction phase. EDP will elaborate a demobilization plan that will be implemented and monitored through the CMAP ensuring adequate communication to workers and government entities prior to and throughout the demobilization process.

Worker’s Grievance Mechanism

EDP will develop an internal labor grievance mechanism aligned with PS2 as required in ESAP item # 15. EDP will broadly communicate to all direct and indirect workers that they can access the labor grievance mechanism. EDP will quarterly report results from the labor grievance mechanism to workers through adequate means such as newsletters or public bulletin boards, or others. The labor grievance mechanism will be able to receive grievances through different channels such as suggestions boxes, telephone, internet and submitted to supervisors or directly to the department of human resources. The labor grievance mechanism will be administered internally by EDP human resources personnel, will allow and address anonymous grievances, and will provide a transparent process to address workplace concerns promptly and without retribution to those who submit their concerns. 

Occupational Health and Safety

The plans and procedures being developed as part of the ESMS will include occupational health and safety (OHS) management programs commensurate to the risks of the project and will conduct inductions and trainings for all site personnel, thus ensuring that staff and contractors have the necessary skills to identify hazards and carry out their work safely.  Other procedures will include recordkeeping of all incidents, near misses, and follow-up to prevent re-occurrences.   

In addition, and as described in ESAP item # 6 the Company will develop the ESHS bridging documents to ensure that EPC contractors apply always the most stringent OHS management plan, and will implement a comprehensive CMAP (ESAP item # 7) to ensure that all the OHS risks and impacts are being properly managed from mobilization and early works, through the main construction phase and demobilization. Any observation or finding will be included in the company’s action tracking system and tracked to resolution.

OHS plans and procedures for the operation phase will be developed prior to commissioning of the plant, marine terminal and T-Line as part of the ESMS for operations, described in ESAP item # 2.

Workers Engaged by Third Parties

EDP will ensure that relevant parts of their human resource policies and procedures will be extended to cover the labor practices of contractors and sub-contractors (e.g. compliance with local laws, non-discrimination, provisions to ensure timely payment of salaries, no child and forced labor, occupational health and safety plans and procedures, etc.)  EDP will monitor the performance of the EPC contractors through the assurance plan defined in the CMAP and will ensure that labor conditions are in compliance with Salvadoran regulations, contractual requirements and aligned with IFC PS2.  Monitoring will include regularly scheduled and un-scheduled audits, review of the EPC contractor internal monitoring reports and documentation, as well as review of grievances logged by contractors and subcontractors’ employees.                                                   

 Resource Efficiency

EDP will use 19 x 18.9MW Wärtsilä’s 50SG Flexicycle units. Each engine will have a Heat Recovery Steam Generator (HRSG) producing steam to power a 26MW steam turbine for a 378MW combined cycle output. In a combined cycle mode, the waste heat from the reciprocating engines is captured in the HRSG, which transforms the waste heat into steam energy to drive a steam generator. The steam generator provides a secondary source of electric generation, making a combined-cycle system more efficient, optimizing the generation of electricity per unit of natural gas input. The overall efficiency of the plant is approximately 49%.

The technology and design of the plant were selected due to the need to provide a high partial load efficiency for fast and frequent startup and shutdown to rapidly adjust to small changes in the energy and power local market demand as needed for El Salvador’s relatively small electrical grid.

Another resource that the project is aiming at efficiently managing is water. The project has been designed with roof mounted air-cooled heat rejection system (Fin Fan coolers) as a mean to remove heat, thus significantly reducing water needs of the project.

Water Use & Wastewater Treatment

Water needs during the construction of the project will not be significant.  Water will be used for the irrigation of internal roads within the perimeter of the plant construction premises during the dry season to suppress dust, for cement preparation and other temporary uses.  During plant operations, the project water demand is estimated at 324 m3/day. Water will be sourced from two permitted groundwater wells located on the east side of the plant premises.  EDP has obtained the corresponding water extraction permits from the National Administration of Aqueducts and Sewers and the Environmental and Natural Resources Ministry of El Salvador (ANDA and MARN for their Spanish acronyms).  Water extraction volumes and rates are not impacting other permitted wells in the area used for drinking water source for nearby communities, as confirmed by the hydrogeological study performed as part of the project ESIA. The study included the assessment of hydrogeological characteristics of the aquifer, the inventory of existing wells, basin hydrology and geomorphological characterization, modelling, water storage and aquifer recharge analysis.  The study confirmed that there is no affectation to other users by the project in the area, and that groundwater infiltration in the basin is sufficient to supply existing and future demand for all the users, including EDP, as the basin receives a transfer of groundwater from the watersheds of the Banderas and Sensunapán Rivers. 

EDP has committed the project to perform permanent groundwater monitoring to assess water quality and ensure the extracted water meets project water quality criteria, as the projected wells are very close to the marine environment.  Monitoring will be performed through two new 100m depth monitoring wells that will be drilled on the west side of the plant (i.e. closer to the shoreline) and equipped will piezometric tubes, and continuous logging equipment to monitor any potential water quality changes. 

Wastewater streams during construction include: (i) effluents from hydrotest water, (ii) drilling fluids and cuttings from the subsea pipeline directional drilling, (iii) portable toilets waste, (iv) rain runoff from unpaved construction areas.  In operations liquid waste streams include: (i) treated effluent from the power plant wastewater treatment plant, (ii) treated effluents from the FSRU wastewater treatment plant, (iii) discharges from the oil and water separator, (iv) runoff management from the storm water management system that will be built, (v) boiler blowdown, and (vi) reject water from the drinking water treatment plant, (vii) bilge from the FSRU. 

As per ESAP item # 16, EDP will develop and implement a liquid effluent management and monitoring plan to systematically manage all liquid and semi-liquid effluents from the project during construction and operations. The plan will include a clear definition of objectives, targets, responsibilities for EDP, for the EPC contractors and for the operators of the plant and the marine terminal, planned management and monitoring activities, project environmental standards for each discharge, and key performance indicators and reporting requirements. As indicated in the ESIA, the project will adopt the most stringent standard of IFC guidelines and Salvadorian regulatory requirements.

The regasification process on board the FSRU will consists of four trains with a capacity of 93.3 million cubic feet of gas per day (MMPCD) each. The LNG will be pumped from the storage tanks of the FSRU to the shell and tube vaporizers where a closed-cycle freshwater glycol system is used to vaporize the LNG. The water with glycol is subsequently heated in a second shell and tube heat exchanger.  The heat of the regasification plant will be provided by seawater.  In addition, seawater is also used for the FSRU boiler and engines cooling system. As a result, during the regasification process, the FSRU will uptake 11,200 m3/hour of seawater, and release the same amount of cooled and heated seawater into the marine facilities surrounding waters. Base temperature for seawater intake is 28ºC, with the water being returned 5ºC colder or warmer depending on the discharge.  EDP’s dispersion analysis confirms that the warm and cold discharges from the FSRU will allow maximum mixing of the thermal plume to ensure that the temperature is within 3ºC of ambient temperature at the edge of the mixing zone as indicated in WBG LNG EHS guidelines.

GHG Emissions

The ESIA identifies the Project operations’ following sources of GHG emissions: (i) natural gas combustion in the power plant; (ii) Sulfur hexafluoride or SF6 leaks from high voltage switches and sub-station; (iii) the operation of the FSRU; and (iv) LNG and natural gas leaks from the maintenance and storage systems, including fugitive emissions.  With a planned 69% plant utilization per year, the estimated GHG for Scope 1 emissions of the plant is 1.74 million tCO2/year. The project will not purchase energy from the grid.

As per ESAP item # 17, EDP will provide a more detailed GHG inventory covering the Scope 1 and 2 as prescribed in the GHG protocol from World Resources Institute and the World Business Council for Sustainable Development for all project components, track them accordingly and report them on an annual basis. EDP will also develop as part of the ESAP item: (i) a boil-off gas management plan following industry best practice to adequately manage and minimize any potential release of methane to the atmosphere from the FSRU, the LNG vessel and any other project component; and (ii) a SF6 management plan, to manage and minimize the use and leaks of this greenhouse gas that has a significantly higher global warming potential than CO2.

Pollution Prevention

The project design includes footprint minimization and pollution prevention and abatement strategies in line with the overarching mitigation hierarchy to avoid significant impacts to the environment and communities. Examples of these include: (i) good facility siting study with the power plant and marine facilities located in brownfields areas; (ii) significant efforts made to avoid impacts for the T-Line route, including a 1,8 km long underground section to avoid adverse visual impacts in the “Ruta de Flores” touristic area; (iii) an LNG marine import terminal consisting of a Restricted Catenary Mooring system which avoided the need for the previously designed cofferdam with a larger environmental footprint and that included dredging and intrusive construction methods; (iv) a subsea natural gas pipeline to be constructed with Horizontal Directional Drilling (HDD), micro-tunneling or equivalent trenchless methodology. 

Several pollution prevention measures are planned for the construction and operation of the project as well.  These include:  liquid effluents management and treatment prior to discharge, irrigation of roads and use of covered trucks to prevent dust generation, hazardous substances management, solid waste management applying the waste management hierarchy, surface runoff, environmental control of work fronts and activities. As indicated in ESAP item # 7, EDP will develop a comprehensive ESHS CMAP describing the controls to ensure that all the ESHS risks and impacts, including pollution prevention, are being properly managed during construction.  The development of an ESMS aligned with ISO, OHSAS standards, and IFC PS (ESAP items # 1 and # 2) will provide EDP with the necessary framework to conduct operations in an environmentally and socially sound manner.

Air Emissions and Ambient Air Quality

Baseline air quality monitoring continuously performed for 101 days in 2016 as part of the ESIA for the power plant indicates the air-shed is non-degraded for particulate matter, Nitrogen dioxide (NO2), Sulphur dioxide (SO2), Carbon monoxide (CO), and ground level Ozone (O3). Measured concentrations of these substances were all below the applicable Salvadorian regulatory limits.

Expected air emissions from construction activities include mainly combustion gases from energy generation and construction related vehicles, machinery, and particulate matter (dust).  Key control measures to be implemented include dust suppression through covered transport of excavated soil, watering of dirt roads and areas of open soil for control of particulate matter, regulated vehicles speed, and regular road maintenance.

The air impacts during operation will be generated through the combustion of natural gas at the plant with emissions primarily of NOx, CO and CO2. Small amounts of air emissions during operation can also be expected from vehicles, LNG vessels, the FSRU, and emergency diesel generators, the latter of which will be operated infrequently. According to the technical specifications, plant emissions will meet the emission standards set forth in the IFC EHS Guidelines for gas-fired reciprocating engines and applicable Salvadoran. The maximum predicted in-stack concentration of Nitrogen Oxides will be 185 mg/Nm3 (at15%O2 content) which is below the reference value of 200 mg/Nm3 for reciprocating engines of the WBG EHS Guidelines for Thermal Power Plants. 

Stack emissions will be measured after the start-up and commissioning of the engines. The proposed monitoring methodology is in line with the United States Environmental Protection Agency (US EPA) approved procedures. Sampling will be carried out by an independent and qualified laboratory and reported to regulatory authorities. Monitoring will be performed annually for three years and if the results comply with project standards, monitoring will be done every two to three years. 

The project stacks were modeled at Good Engineering Practice (GEP) height consistent with the selected stack design. Results of the dispersion modeling show that the project will meet both the Salvadoran 24hr and annual averaging period standards for NO2 for both the project alone and when combined with the ambient NO2 concentrations as shown in the results from the ambient air quality monitoring station located in the community of Acajutla.

While the modeling results for the annual NO2 averaging period show the maximum impact will be well below the IFC’s 25% guideline, results for the 24-hour NO2 will exceed the guideline. The maximum 24hr NO2 concentration of 134.06 ug/m3 represents 89% of the ambient air quality standard. Modeling results show the project would exceed the 25% guideline with a frequency of 8.2% (on average 30 days per year). Modeling results show that the highest 24hr NO2 concentrations would occur in the adjacent port and industrial area in close proximity of the project with limited impact at sensitive receptors in the residential community of Acajutla.

The cumulative airshed analysis showed that the predicted maximum concentrations at the monitoring location (within the community of Acajutla) for both the 24hr and annual average NO2 concentrations for both the three existing facilities alone and the three existing facilities and the EDP project combined were all well below their respective ambient air quality standards. Another important factor with regards to the 25% guideline is that the baseline 24hr NO2 concentration as measured at the monitoring station represents 7% of the applicable ambient air quality standard. Based on these factors and considering that the project will use natural gas, it is likely that the project as designed will not significantly limit the potential for future development of industrial facilities in the general area based on existing and future 24hr NO2 concentrations.

Operational monitoring (deployment of an additional ambient air quality monitor for NOx) is proposed in ESAP item # 18 to monitor and verify the project’s predicted impacts on ambient air quality.   EDP will operate and maintain two continuous ambient air quality monitoring stations to include the existing monitoring station located in the community of Acajutla and a new monitoring station to be located in the area of the highest predicted NO2 impact.

As indicated in ESAP item # 19, EDP will develop a robust stack emissions and air quality monitoring program, fully integrated within EDP’s management system to ensure that monitoring results are constantly assessed, trends and KPIs are analyzed and timey reported to plant operations and senior management. This will allow to proactively assess the effectiveness of the monitoring program.

Environmental Noise

EDP’s power plant will be located west of an existing power plant which is the dominant source of noise in the area. Although the area is an industrial complex, there are residential receptors to the northwest, north and southeast of EDP’s proposed power plant, with the closest receptors located near the artisanal fishing pier.

The ESIA presents background continuous noise monitoring readings from four monitoring stations close to the receptors. The maximum noise levels measured during the daytime at all monitoring sites were below the 55 dBA. Noise levels measured at night time recorded one station below 45 dBA and three with background noise readings above this standard.  The project will ensure that environmental noise during operations is within the recommended standard for residential receptors, and in any case, won’t result in a maximum increase in background levels of 3 dBA in line with IFC requirements. 

Environmental noise monitoring will be performed annually for the life of the project on the same four baseline monitoring stations to verify compliance with project adopted standards and recorded any variation against baseline conditions as a result of the project. In addition, and as part of the stakeholder engagement activities EDP will respond to any concerns of the community regarding environmental noise as a result of the operations of the facility.

Solid Waste & Hazardous Waste Management

As reported in the ESIA, solid waste generated during construction and operations will be temporary managed in the waste storage areas of the power plant, segregated at the source, recycled and transported by licensed contractors to government approved facilities.  Handling of hazardous waste in the operation stage is also discussed in the ESIA, which requires EDP to transport hazardous wastes offsite by specialized contractors and contained/treated in licensed storage facilities.

As indicated in ESAP item # 20 EDP will develop a detailed waste management plan in line with IFC Performance Standards and with due consideration to Section 1.6 of the WBG EHS general guidelines and specific waste related requirements set forth in the WBG EHS guidelines for thermal power plants. The waste management plan will be included in the management system that is being developed by EDP, who will ensure compliance from the EPC contractors working in all the components of the project.                                                  

 Infrastructure, Equipment Design, Hazardous Materials Management and Safety

The power plant is located in a brownfield port and industrial complex, which reduces some potential E&S impacts to surrounding communities.  Inside the port, access roads to the project area are already available and in use for all the road traffic derived from the port’s activities.  Most materials and equipment for the project will be delivered by sea directly to the port of Acajutla, limiting the use of external access routes. A temporary laydown area for construction of the plant will be habilitated within the port’s free area.

EDP will not provide workers accommodations, but is expected to provide transportation services for workers from nearby communities.  Transportation of personnel and materials from San Salvador and other areas of the country is not expected to cause a significant traffic increase on public roads.  EDP will develop a workers’ transportation management plan (ESAP item # 5) in consultation with municipalities, local communities and schools as indicated in the ESIAs.  It will include guidelines for the use of collective transport for workers to reduce vehicle movement, control speed limits, use of defined routes, schedules, training for drivers and traffic control signals in order to reduce traffic related impacts such as noise, dust, vibration and emissions in neighbouring communities. 

In order to mitigate potential impacts of immigration to the project area by people in search of jobs or other economic development opportunities, and to prevent and manage the risks of proliferation of infectious diseases and social conflict, EDP will develop an influx management plan as indicated in ESAP item # 5.  The plan will cross-reference other relevant plans such as local hiring, workers’ transportation and stakeholder engagement, and will seek to coordinate efforts with the municipality of Acajutla to avoid overloading social services in the area.

As part of the ESIA commitments, EDP will develop a marine safety traffic plan. The port authority has established an exclusion zone around the port that will be expanded to include the FSRU.  Artisanal fishers often enter the port’s area.  EDP will coordinate with the port authority to monitor and prevent fishers from entering the exclusion zone once the RCM system installation and the laydown of the subsea pipeline starts. Potential impacts to fishers from LNG vessel traffic is considered minimal as LNG vessels are expected every two months during plant operations. The port authority can easily and safely accommodate the small increase of marine traffic in close coordination with EDP.

EDP will develop as per ESAP item # 5, a fishers’ management plan that will include measures to reduce the possibility of incidents during the marine terminal operations. In addition, and as part of its stakeholder engagement plan, EDP will provide information to fishers regarding LNG vessel traffic in advance to prevent incidents and keep the stakeholders informed about the marine facilities activities.

Emergency Preparedness and Response

EDP will ensure that through stakeholder engagement programs the EPRPs listed in ESAP items # 9 and # 10 are disclosed, and information about potential emergency scenarios as well as potential impacts on communities and fishers will be communicated.  Emergency response training will include processes to ensure that potentially affected stakeholders are adequately informed in case of emergencies and know how to proceed under these circumstances.

Security Personnel

EDP has contracted the services of Lamb’s Security Solutions to develop a security risk assessment for the construction and operations phases, as well as to support the development and implementation of a security management plan. The plan will be developed with a strong focus on prevention and risk mitigation for the protection of personnel, facilities, equipment, operations and communities with full respect to human rights.  As per ESAP item # 21 the security management plan will be based on a robust assessment that will examine risks associated with security arrangements to those within and outside of: (i) the port facilities, (ii) EDP’s footprint, including the T-Line and transportation routes and (iii) offshore area, to the extent that these security arrangements are relevant to EDP.

EDP’s security management plan will: (i) define security management objectives; (ii) discuss internal and external risks identified in the security risk assessment; (iii) define how EDP will screen private security firms and guards and provide adequate training; (iv) define conditions for use of force; (v) define how coordination between private and public security forces will occur; (vi) define incident reporting; (vii) describe how the company will engage with individuals, communities and fishers and report on security matters; and, (viii) establish KPIs for security performance assessment.  EDP will also liaise with CEPA, with the Salvadoran Navy and port authorities to ensure that their security arrangements are aligned with EDP’s including the review of security incidents and mechanisms to address them.                                                  

 The power plant is located within the port of Acajutla, a brownfield industrial complex in western El Salvador and considered a Modified Habitat per PS6 definitions.  The marine terminal is located within a marine Natural Habitat per PS6 definitions due to the undisturbed state of the marine ecosystem and native species present in the area.  Although the plant and marine facility are not located within any legally protected area or internationally recognized areas of conservation importance, they are close to and between two natural areas: Barra de Santiago Natural Protected Area (17 km west) and Los Cóbanos Natural Marine Protected Area (6 km south-east).

The T-Line crosses several World Wildlife Fund (WWF) Ecoregions including the Central American Montane Forest, the Central American Dry Forest, and the Central American Oak Forest. The T-Line crosses a mosaic of Modified and Natural Habitats from lowland agricultural fields and dry forest remnants of the Los Cóbanos Important Bird Area (IBA), to the buffer zone of the Apaneca-Ilamatepec Biosphere Reserve. Of significant importance is that the majority of migratory flyways between North and South America are compressed as they pass through Central America, resulting in seasonally high densities of migratory birds in these countries.

Two ESIAs were prepared for the project. Data on biodiversity values were obtained through a combination of desktop reviews and field surveys for herpetofauna, birds, and mammals in terrestrial habitats, and for marine invertebrates (oysters, corals, mollusks), sea turtles, and both freshwater and marine fish in marine habitats.

Priority biodiversity values associated with the marine terminal were identified as follows: (i) the Green sea turtle (Chelonia agassizi – IUCN Red List Vulnerable [VU]), (ii) the Leatherback sea turtle (Dermochelys coriacea – VU), (iii) the Hawksbill sea turtle (Eretmochelys imbricate – IUCN Red List Critically Endangered [CR]), and (iv) the Olive Ridley sea turtle (Lepidochelys olivácea – VU).   While no sea turtle nesting has been reported on Acajutla beach just north of the project area, EDP is located at the northern end of an important stretch of turtle nesting beaches and between two protected areas, thus sea turtles are likely to cross the project area in the sea frequently.  No fish species of conservation concern were documented during the field surveys.

With respect to biodiversity values along the T-Line, the most important is its location within the migratory flyways of a number of bird species. Other species are reported to be associated with the project’s area of influence. These include, inter alia: (i) plants: Eugenia salamensis -EN, Juglans olanchana – EN, Swietenia humilis – VU, Quercus skinneri – VU, Cedrela odorata – VU; (ii) birds: Chocoyo, Orange fronted parakeet (Eupsittula canicularis – VU), Catalnica, Orange chinned parakeet (Brotogeris jugularis – VU); (iii) amphibians: Black-eyed Tree Frog (Agalychnis moreletii – LC), (iv) reptiles: Black spiney-tailed iguana (Ctenosaura similis – LC); and mammals: Crested-tail deer mouse (Habromys lophorus – LC), Woolly false vampire bat (Chrotopterus auritus – LC).

The project has made considerable efforts to adhere to the mitigation hierarchy, avoiding and minimizing impacts through project design to a great extent. The marine terminal design was modified from a cofferdam and dredged area to an FSRU with a RCM system, which will substantially reduce the footprint and impacts on the sea floor during construction. The main impacts during operations include lighting pollution, thermal water discharges from FSRU and increased marine vessel traffic.

With respect to the T-Line, the main impacts to biodiversity are related to vegetation loss due to the installation of transmission towers, and potential collision of birds with T-Line cables, which is especially important with respect to large-bodied soaring birds, including migratory birds. The T-Line ESIA assessed the potential impacts with regards to collision of birds, and determined the need to install bird flight diverters in nine selected sections of the ROW. Approximately 460 spiral-type diverters will be installed in the locations of highest risk with respect to collisions with soaring birds, including any migratory birds.   The ESIA also identifies the need to perform monitoring of the effectiveness of the bird-saving devices, preferably in the months when migratory birds are present.  Results will be assessed by biodiversity specialists and recommendations included in the company’s E&S management system.

With respect to the marine terminal, on-site minimization includes inland rainwater management to prevent sediments into the marine environment, a lighting management plan to minimize impacts to marine fauna, turbidity and water quality monitoring, implementation of a marine wildlife rescue center in collaboration with Ministry of Environment and Natural Resources (MARN) for the recovery of marine animals that could be affected during construction, prohibition of fishing or hunting, training program on wildlife conservation, terrestrial fauna rescue and relocation program. The construction of the marine terminal also includes directional drilling to install the subsea pipeline, avoiding impacts on the beach and minimizing impacts in the marine environment.

In the case of the T-Line, great effort has been taken to avoid protected areas, natural reserves and placing towers in areas with good accessibility to reduce construction of access roads, and the installation of flight diverters.  Four possible main alternatives for the T-Line corridor connecting the substation of Acajutla and Ahuachapán were identified and assessed.  As a result of all the avoidance measures considered in the design, a total of 27.75 Ha of Natural Habitat, and 37.56 Ha of Modified Habitat will be impacted. The 44-km T-Line crosses the north-west edge of Los Cóbanos Important Bird Area (IBA) for 2.89 km and the Apaneca-Ilamtepec Biosphere Reserve buffer zone (4 towers) and transition zone (12 towers).

With respect to the Los Cóbanos IBA the project established a communication and consultation mechanism with relevant stakeholders, including the SalvaNATURA (local partner of BirdLife International).  The project will also be developing a reforestation plan per MARN requirements (10:1 for all trees, 25:1 for protected species) to be undertaken by a NGO or community development association. The project has also developed an environmental education program for local stakeholders regarding the importance of this IBA and objectives for conservation.

As indicated in ESAP item # 22 EDP will develop a “Biodiversity Management Plan” (BMP) to summarize all important biodiversity values, project impacts and biodiversity mitigation actions to be carried out, with timelines, roles and responsibilities, and planned activities, with key performance indicators and reporting requirements, especially for the Apaneca-Ilamatepec Biosphere Reserve and the Los Cóbanos IBA. The project will conduct an independent review, using an ornithologist specialized in the impacts of transmission lines on birds, to identify the most suitable bird flight diverters to use, considering weather conditions and technical considerations, and to identify long term maintenance measures, if any, and costs.  The outcomes of the review will be integrated into the BMP.

In ESAP item # 23, EDP will develop a Biodiversity Monitoring and Evaluation Program (BMEP). The BMEP should establish a biodiversity baseline and monitoring protocols and targets for all components of the project to evaluate and demonstrate No Net Loss of biodiversity as required by IFC PS6.                                                  

 Information Disclosure & Consultation

EDP has complied with project disclosure and public consultation requirements of the environmental licensing process in El Salvador and with PS1 stakeholder engagement requirements.  EDP developed and implemented a plan outlining activities of stakeholder engagement for the ESIA process. Key stakeholders engaged include local communities, fishers and fishers’ organizations, CEPA, municipality of Acajutla, local Institutions such as schools and health centers and commercial organizations.  The disclosure and consultation processes for the power plant and marine terminal have included project awareness through national and local media, meetings and presentations with key organizations, workshops with local communities and two open public hearings.  In accordance with local requirements, EDP allowed for a 10-day period of consultation, and public concerns were incorporated and responded as part of the ESIAs technical observations process.  In addition, EDP has a community liaison office in the town of Acajutla where EDP staff provides information and addresses concerns from the public.

Consultations have been carried out in a participatory manner and all findings (including list of attendees) are recorded in official meeting minutes.  Community members emphasized their interest in employment opportunities, potential social and economic development through business opportunities and the social investment fund and training programs.  They also expressed concerns associated with potential project impacts such as noise, air emissions, marine pollution, emergency incidents and restrictions to fishing activities.

Stakeholder mapping / analysis

EDP has mapped general stakeholders in their area of influence and will strengthen this effort as part of their SEP. EDP will conduct annual stakeholder mapping exercises to identify stakeholders, to adjust their type of relationship with and interests in the project, and to plan engagement activities.  Through the stakeholder engagement mapping exercise, EDP will identify vulnerable groups and will focus their efforts on job seekers, artisanal fishers and the most affected and influential stakeholders in the Acajutla area and along the T-Line corridor.

Stakeholder Engagement Plan

EDP will develop a stakeholder engagement plan that aligns with IFC PS1 as part of ESAP item # 5 for the construction phase. The plan will include the following elements: (i) company’s description; engagement principles, objectives and criteria for stakeholder engagement; (ii) local regulations and lender requirements; (iii) description of key social and environmental risks and impacts; (iv) summary of previous engagement activities and stakeholders’ concerns; (v) identification, analysis and prioritization of stakeholders, focusing on those directly affected including vulnerable groups, fishers, job seekers, residents along the transmission line and residents of Acajutla; (vi) action plans to be updated annually describing specific activities that will be conducted by EDP to communicate ESMS plans, engage stakeholders and solicit feedback; (vii) description of EDP’s grievance mechanism and description of how EDP will monitor contractors’ grievance mechanisms; and (viii) timetable, resources, and responsibilities.

The SEP will also cross-reference other relevant management plans implemented by the company to manage environmental and social risks and impacts. The community relations coordinator will ensure proper implementation of the SEP as well as resourcing and management of the community relations team as needed throughout the construction and operation phases of the project.  EDP will update the SEP for each phase of the project, and as appropriate when required by project or context changes.

External Communications and Grievance Mechanisms

EDP defined the elements of a grievance mechanism in the ESIA.  As per ESAP item # 5, EDP will develop and implement an external communications procedure and a community grievance mechanism that includes methods to: (i) communicate the grievance mechanism to communities and other potentially affected people; (ii) receive and register external communications from the public; (iii) screen and assess the issues raised and determine how to address them; (iv) provide, track, and document responses; (v) provide feedback to stakeholders on grievance mechanism results; and (vi) definition and monitoring of key performance indicators (KPIs), as appropriate.

The grievance mechanism will seek to resolve concerns promptly, using an understandable and transparent consultative process that is culturally appropriate and readily accessible, at no cost and without retribution to the party that originated the issue or concern. The mechanism will not impede access to judicial or administrative remedies.  Grievances will be able to be submitted via phone, email, directly with the community relations team and through other means as appropriate for the local conditions.

Ongoing Reporting to Affected Communities

EDP community relations team will meet regularly with stakeholders to provide ongoing information on project development; environmental and social performance; employment opportunities; demobilization; security management; emergency plans; grievance mechanism; biodiversity as well as air and water monitoring; social investments and fishers support programs.  Other programs will be disclosed as they are developed.  EDP’s SEP will include an action plan that defines specific engagement actions, frequency and KPIs and which will be updated annually.