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 proposed project and the route of the pipelines are located in an area devoid of human settlements. Thus, PS 5 – Land Acquisition and Involuntary Resettlement is not considered applicable.

The ecological survey conducted as part of the ESIA showed that there are no flora or fauna species of particular importance existing along the modified pipeline route. The results revealed that the vegetation has had anthropogenic alterations, is extremely sparse and highly limited in terms of species, and without evidence of fauna. This may be partially attributed to industrial facilities surrounding the project site. As part of the ESIA conducted for the dredging operations, EHC commissioned an underwater survey of the marine life conditions in the proposed project area and the assessment revealed very poor and limited marine life. The survey encountered total mortality of coral reefs and other marine life at the quay wall area and down drift most likely due to severe man-made interaction since about 35 years previously. The assessment also revealed the presence of sea urchins and of debris (i.e., ropes, pieces of fishing nets, drowning materials, etc.) Therefore, PS 6 - Biodiversity Conservation and Sustainable Management of Living Natural Resources is not applicable.

Furthermore, the project’s area of influence is located in areas absent of communities that would be considered as ‘Indigenous’ as defined by the World Bank Group, thus PS 7 - Indigenous People is not considered applicable. Archaeological and historic sites were not found within the project site’s boundaries, thus PS8 - Cultural Heritage will not apply.

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. Key environmental and social impacts associated to this type of operation include environmental and social management, air emissions, liquid effluents, workplace noise and chemicals exposure, handling of hazardous materials and community related impacts.

The proposed investment qualifies as a Category B project as defined by IFC’s Environmental and Social Sustainability Policy (2012) because of potentially limited environmental and social impacts that may result from the expansion or operation of the existing facilities, all of which can be avoided or mitigated by adhering to generally recognized good practices and design criteria. The company has objectives and plans that seek to address environmental and social risks and impacts in accordance with Egyptian laws and relevant IFC Performance Standards (PS), including the applicable elements of the World Bank Group (WBG) General Environmental, Health, and Safety (EHS) Guidelines; the EHS Guidelines for Nitrogenous Fertilizers Manufacturing, and Petroleum-Based Polymers Manufacturing; and the attached Environmental and Social Action Plan (ESAP).

Environmental and Social (E&S) Assessment

For purposes of assessing the impacts of the project, CH; (a) assessed the EHS status of OPC based on previous assessment reports conducted by Egyptian health, safety and environment consulting firms dated 2000 (EIA), 2007 (Safety & Occupational Health) and 2009 (Environmental Monitoring); (b) commissioned and an international environmental consulting firm prior to construction to develop the environmental and social assessment (ESIA) for EHC which was completed in 2010; and (c) engaged an Egyptian environmental consultant firm prior to expansion of the port to conduct the ESIA for the port enlargement activities which was completed in 2014. The Egyptian Environmental Affairs Agency (EEAA) issued environmental operation permit for OPC and environmental construction permits for EHC and the port expansion activities. The assessments conducted align with IFC’s requirements.



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

CH’s corporate EHS structure is still in development. The EHC and OPC environmental, health, safety and social aspects are being addressed at the site level. Thus, as part of the project, CH will establish and implement a corporate Environmental, Health, Safety, and Social Management System based on the Egyptian regulations; IFC’s PSs; the relevant WBG EHS Guidelines; and internationally recognized EHS and social standards (i.e. ISO 14000 and OHSAS 18000) as indicated in the ESAP. The Management System will include; (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) development and implementation of Community Outreach Programs. Currently, OPC is working towards getting ISO 14001 and OSHAS 18001 re-certifications and EHC is committed to pursuing ISO 14001 and OHSAS 18001 certifications for the production phase.



Even though while operating OPC had safety operational procedures, the company is currently reviewing those prior to restarting operations. For EHC, the company has developed many of its operational phase safety operations procedures, copies of which it will submit to IFC as indicated in the ESAP. A few pending procedures are to be developed and include; (a) the emergency response procedures for the plant; and (b) the emergency response transportation of the MGAN from the site to port. Once developed, copies of these will be also submitted to IFC as per the ESAP.



To ensure sound EHS contractor performance, OPC and EHC have developed detailed procedures including contractual contractor clauses about EHS compliance (i.e. use of personnel protective equipment (PPE), work permits, report of incidents/accidents, compliance with local labor laws, etc.). During the construction phase, while liaising with and being accountable to EHC’s EHS Manager, the contractor’s EHS personnel has been
responsible for the successful implementation of and continuous compliance with all EHS policies, procedures and requirements applicable to the project during this phase. In addition, EHC conducts periodic EHS performance evaluations to the contractors to ascertain their EHS performance.

OPC and EHC have dedicated qualified personnel to handle the EHS aspects during construction and operation. Each of the companies has a dedicated HSE manager, reporting directly to the Chairman & CEO and General Manager, and supported by a team of qualified EHS personnel (engineer, supervisor, trainer, technician, medical doctor, fire brigade, etc.) CH also has a corporate EHS Director who currently also functions as the EHS manager at EHC. As appropriate, OPC and EHC have personnel responsible for community relationship reporting directly to the Chairman. As needed, CH also hires environmental consultants, to conduct studies, monitoring, audits, etc.



Emergency Preparedness and Response

OPC has an Emergency Response Plan that considers appropriate emergency preparedness and response measures to implement in the event of a fire, leak, spill, etc. As part of its emergency response planning, once the operation restarts, the company will have trained emergency response personnel available at all times, will involve the local authorities in the development of the emergency response planning as appropriate, and conduct periodic emergency drills. Worth noting, that the plant has not had any major incidents.

For the construction phase, EHC along with its contractor has also developed an emergency response plan and has trained fire and emergency brigades available at all times. In addition, for EHC’s operation phase, the company will have an emergency response plan and qualified personnel to respond to any emergency that may arise. Periodic emergency drills will be also conducted.



Training, Monitoring, and Reporting

CH is set to conduct rigorous safety training at each plant. OPC conducted and, once operational, will continue conducting induction training for all employees and periodic EHS training on relevant safety topics (e.g., safety audits, job hazard analyses, emergency preparedness, CPR, fire prevention, electrical hazard, collection of accident and near miss statistics, confined space, working at height, chemical handling, etc.) For EHC, it has already identified the type of training to be covered during the operation phase.



While in operation, OPC activities were periodically monitored. Parameters measured included stack emissions, working environment and ambient air conditions. Once operational the monitoring program will be reinitiated and modified as required. EHC’s contractor has conducted monitoring during the construction phase. Parameters measured include ambient air quality, groundwater/water quality, and noise levels and work related accidents, incident, etc. EHC also supervises the contractor to ensure its compliance wi
th the contractually agreed EHS aspects. For the operating phase, EHC will establish continuous emissions monitoring and it will conduct quarterly active ambient air monitoring of PM10, SO2, CO, NO2, NH3 and VOC. It will also measure ambient noise, drinking water characteristics, groundwater, workplace conditions (dust, thermal stress, vapors, etc.) and sea water characteristics at the port. The environmental monitoring records are made available to the environmental authorities.



Engagement, Communications and Grievance Mechanisms

CH Director, Government and Community Relations, manages external communications and overall engagement with project stakeholders. External communications involve keeping the stakeholders informed of CH’s growth strategy and operations CH engages with stakeholders and communities in an open and transparent manner. CH operations are located in an industrial area and overall have minimal interaction or risks and impacts on local communities. As part of the ESIA for EHC, the company conducted 4 public hearings and received the community approval for the plant and the berth.



CH has yet to develop a grievance mechanism (GM) for communities, for collecting or addressing concerns or complaints from local or directly affected communities. CH will develop and implement a GM scaled to the risks and adverse impacts of its operations to receive and facilitate resolution of affected communities’ concerns and grievances about CH’s environmental and social performance in alignment with PS 1 requirements. Copy of the GM will be submitted to IFC as indicated in the ESAP. The mechanism will include: (a) methods of communication about the mechanism to communities (i.e. existence of the grievance mechanism); (b) means to present the grievances, process of resolution, etc.; (c) process of receiving and registering grievances/ complaints; (d) assessment and categorization of grievances; (e) prioritization and hierarchy of grievances and response time; (f) guidelines for resolution and response of grievance; (g) responsible personnel in charge of resolution; (h) documenting grievance/resolution; and (i) periodic monitoring of grievances.

Working Conditions, Management of Worker Relationships and Protecting the Workforce

CH’s Human Resources (HR) policy and procedures include aspects related to equal opportunity employment, recruitment, employees’ conduct, employment regulations, salaries, disciplinary code, employees’ grievances, and performance management. CH’s HR manager is responsible for ensuring CH’s compliance with its HR policy, Egyptian laws and regulations affecting all employees including contractors. CH’s labor policy is aligned with IFC PS2 requirements stating that CH will not use forced labor, whether in the form of prison labor, indentured labor, bonded labor or otherwise and will only hire employees who meet local minimum age requirements. The labor policy also includes provisions relating to non-discrimination and equal opportunity, wages and benefits and occupational health and safety. CH is an equal opportunity employer that extends equal employment opportunity to all applicants and its selection decisions are merit based. Even though, CH employees have right to freedom association, currently its labor force is not unionized and there is an overall positive labor climate.



Once operational, OPC anticipates having 322 direct employees (10 female) and 20 indirect employees (9 female). Currently EHC has 215 direct employees and 91 contracted employees. It is anticipated that for the operational phase it will have 220 direct employees and 100 indirect/contracted employees. An estimated 15 of 320 or 5% will be women.



CH’s HR Policy and Procedures incorporates a grievance mechanism for resolving worker issues concerning employment and working conditions internally for its own and contracted employees. The workers’ grievance mechanism defines the channels (e.g. mail, phone, verbal report to immediate supervisor/reporting authority; etc.) available to submit grievances, including anonymous reporting, and the internal procedure for its handling. Once both OPC and EHC are operational, CH will ensure that they implement the employees’ grievance mechanism, will ensure its employees are aware of the existence of this grievance mechanism and it will inform IFC, as indicated in the ESAP, about the mechanisms to be used for providing this information to its employees.



Occupational Health and Safety (H&S)

CH aims to establish a health and safety (H&S) management system to ensure zero accidents across all operations. OPC has had an overall good safety record. While operating, the company focused on the prevention of risks related to work at heights, work with live power lines and equipment, fire, exposure to chemicals, exposure to electromagnetic fields, etc.; and made compulsory the use of PPE (i.e., ear protection when workers noise exposure is above 85 dB (A), safety helmets, safety goggles, mechanical protection gloves, safety shoes, welding masks, full-body harness, etc). Additional safety measures included installing maintenance and enclosures a
nd buffers to ensure noise levels below 85 dB (A), planning daytime activity for heavy vehicles, etc. Furthermore, to identify potential leaks and prevent accidents, OPC has portable gas detectors for hydrocarbons, fixed HC detectors distributed in all units that contain HC gases or liquids, fixed O2 detectors in the closed zones, and fixed H2 detectors distributed inside the hydrogen unit. Once operational, OPC will implement and update as needed its H&S plans and procedures and inform IFC of such updates.



Both plants perform full physical and medical assessment as a pre-employment screening. All employees will have regular periodic medical checkups. The overall medical condition of OPC’s work force (past medical liabilities) is satisfactory and there are no chronic job related illnesses.



OPC operations are fitted with appropriate fire prevention and response services, including automatic sprinkler systems, water supply, water mains and fire hydrants, portable first aid, firefighting equipment, emergency warning alarms, emergency shutdown system and an emergency notification system to inform nearby industries and residential communities of an emergency. Fire and emergency response training will be provided at induction as will annual refresher courses. Fire and emergency response drills will be carried out quarterly.



While operating, OPC had emergency response procedures in place and conducted emergency response training for all employees. A similar approach as defined will apply to future activities. Its emergency response team consisted of a team leader, firefighters and auxiliary firefighting team available 24 hours per day, and a fire truck driver. It conducted monthly emergency drills and had a full time clinic with ambulance. The plant had installed a firefighting prevention/response system including two water tanks with capacity of 10,000 m3 and 5000 m3 each; one jockey pump, and electric and diesel firefighting pumps; firefighting hydrants; monitors; deluge valves covering the entire production area; and a firefighting truck.



As indicated above, EHC required its construction contractor to develop and implement H&S procedures approved by the EHS manager. The construction phase incident/accident records are overall within industry norms. H&S plans and procedures specific to the operation of the EHC facility are being developed as the construction program advances. Copy of these plans and procedures will be submitted to IFC as indicated in the ESAP. The specific measures to be adopted including an H&S organization for operations, and emergency response will be based on hazards and risks identified for the operational phase using standard industry techniques. Fire and life safety protection systems and control facilities will meet international standards for these operations.



EHC will also ensure implementing sound safety measures for the operational phase including ensuring strict housekeeping in part
icular minimizing the accumulation of ammonium nitrate dust in the production and storage areas to reduce risk of dust explosion; placement of emergency showers, self-contained breathing devices, first aid points and wind socks; requiring hot work permits, lock out/tag out procedures, and confined space entry authorizations; requiring compulsory use of PPE; conducting annual non-destructive testing to monitor pipe thickness, etc. Specifically for the ammonium nitrate packaging area, EHC will install a complementary pressure relief device to not only reduce pressure build up to an acceptable level, but also to vent combustion gases and suppressant from the suppression system to the atmosphere. It will also ensure proper grounding and bonding of the bag slitter to minimize the potential for dust cloud ignition by electrostatic discharges and install water sprays, screens or curtains to absorb ammonia in the event of release and to induce more turbulence in the cloud to enhance dispersion. It will also use vaporized nitrogen in the nitric acid and LGAN units as purge gas and storage tank blanket gas as well as for use in purging of tanks, vessels, equipment and piping, when necessary.



EHC will develop a periodic timetable for regular inspection and maintenance for all units including pipelines, it will install emergency warning alarms and emergency shutdown (remote manual shutdown and isolation of unit/plant), all areas with hazardous materials will be stored with adequate secondary containment to collect accidental spills, and evaporation ponds will have double lining. EHC will also have an emergency notification system to inform nearby industries and residential communities of any emergency.



EHC’s firefighting water will be provided from the two desalinated water tanks with a storage capacity each of 15,000 m3 and will supply the firefighting ring main system with firefighting water pressurized by two jockey pumps and by main pumps (electrical and diesel driven.) In addition, the plant will also have hydrants with hose boxes; hose reels for protection of the control, office, and storage buildings; dry risers for protection of the prilling tower; sprinkler systems, gas extinguishing systems a semi-fixed foam system and portable and wheeled fire extinguishers.



OPC and EHC are committed to conduct periodic monitoring and measurement of the work place conditions at all its plants as per Egyptian and IFC H&S requirements. Examples include potential dust emission levels, and noise levels inside/outside the plant.



The dredging contractor has been required to have proper health and safety measures including compulsory use of protective personnel equipment, availability of firefighting equipment, contingency plan, etc.

Resource Efficiency

OPC total electric power requirement is approximately 7MW at maximum production capacity from the grid. Upon resuming operation, the overall power consumption will be assessed and applicable energy efficiency measures will be applied including but not limited to boiler efficiency and the power factor.

EHC’s total electric power requirement is approximately 14 MW of which, 9.7 MW will be self-generated by converting the heat release from the exothermic reaction in the nitric acid plant using steam turbines. The remaining power needs will be supplied by the national grid. EHC will also install an onsite 1 MW diesel-driven emergency generator.



Pollution Prevention

Ambient Air Conditions and Stack Emissions

OPC has a 10 ton boiler that uses 13.4 Million m3/y of natural gas. OPC’s flare and boiler are the sources of air emissions to the atmosphere. The released gases from the process (nitrogen, hydrogen, propylene, propane) are sent directly to the flare system. The liquid hydrocarbons (propylene, propane) are heated prior being sent as gas to the flare. The latest air monitoring conducted in 2009 before the shutdown demonstrated that the company was operating in compliance with Egyptian and the WBG EHS Guideline requirements. OPC will install continuous emissions monitoring for PM, CO, SOx, NOx and, once operation starts, as previously it will monitor ambient air (PM, SOx, and NOx) as well as hydrocarbons and oxygen. Further, OPC will install oxygen and hydrogen detectors throughout the plant to identify potential leaks and to prevent accidents.



As part of the ESIA, EHC conducted ambient air monitoring of SO2, CO, NO2, PM10, PM2.5, NH3, ozone, lead, total suspended particles, and PM. The results indicated that the ambient air quality will comply with national legislation and the associated WBG EHS Guideline. EHC also conducted air dispersion modeling to predict the contribution of NOx emissions from the boiler and nitric acid plant, and of particulate matter from the ammonium nitrate plant to the local air quality at normal conditions, emergency situations, and non-routine operations. The results indicated that the cumulative impact to the background ambient air concentrations with the release of EHC’s air emissions will result in air quality standards being maintained within those defined by the local required and those associated with the WBG EHS Guideline. There will also be a flare at the port for emergency situations.



For the construction phase, EHC has established measures (i.e., regular spraying of off-road tracks, cover stockpiling locations, transport material in closed/covered trucks, etc.) to reduce generation of air emissions. The company has also being monitoring the ambient air conditions during the operational phase and the results reveal that the air conditions have been complying with Egyptian and WBG EHS Guideline requirements.



For the operation phase, the plant will have bag filter
s to control PM emissions, and scrubbers to control gaseous emissions. In addition, the gas turbine generator will be equipped with dry low NOx burners to reduce NOx emissions and it will use low sulphur (8 ppmv or less H2S) natural gas to reduce SO2 emissions. EHC will also control the fugitive emissions from the packaging area by installing a local exhaust ventilation system which in turn it will send the collected emissions to bag filters to ultimately reduce the particulates released to the atmosphere. It will also have portable leak detection equipment to identify and prevent fugitive emissions. For the operation phase, EHC will conduct ambient and stack emissions monitoring as well as install continuous emissions monitoring to measure PM, SOx, NOx and CO.



Green House Gases (GHGs)

OPC has one boiler with 10 tons capacity burning natural gas. The estimated amount of CO2 emissions from this process is estimated to be 25,000 tons of CO2 eq/year.



CO2 will be directly emitted during EHC operations; additionally N2O, which is also a greenhouse gas, is expected to be emitted during the operation of the nitric acid plant. The estimated amount of CO2 from the plant operations is 92,000 ton of CO2 eq/year, and of N2O are 82,000 tons of CO2 eq /year.



Water and Liquid Effluents

OPC’s total consumption is approximately 65 m3/h. The water needs are satisfied by the municipal water system. However, in case of supply shortage, OPC can access groundwater from its onsite wells for which it has a permit.

OPC generates domestic waters and wastewater from the reverse osmosis unit. The wastewater generated at the reverse osmosis (RO) units is diluted to <700ppm of total dissolved solids and used for irrigation on the greenbelt around the plant. The 20 m3/day of domestic waters generated are collected in a septic tank, and trucked to the domestic wastewaters treatment plant.

EHC will consume 69 m3/hr of water which will be obtained from onsite wells, authorized by the Ministry of Irrigation and Water Resources. If additional water is needed, EHC will dig additional water wells within its own premises with appropriate approval from the Ministry of Irrigation and Water Resources. Due to the high salinity and high content of hardness and sulphate, EHC needs to treat and desalinize the raw water before use. A closed cooling water system will be provided as the cooling medium in the nitric acid and ammonium nitrate units.

EHC will generate the following wastewaters: (a) concentrated brine from the RO process; and (c) sanitary wastewaters. EHC is being designed to operate as a zero discharge system. All residual wastewaters will be passed through an oil and grease separator, as needed, prior being routed to an evaporation pond, which comprises of 4 basins, for final disposal. In addition, wastewater with small quantities of nitric acid will be neutralized prior being discharged into the evaporation pond. The pond sludge will be removed reg
ularly and analyzed to be classified (hazardous/non-hazardous) and consequently sent to the appropriate disposal/treatment facility by a licensed waste handling contractor. In the instances when the brine treatment unit may not be available, the highly concentrated brine will be discharged via a separate line into the evaporation pond. The sanitary wastewater will be treated in a biological treatment unit. The treated effluent will be disposed into a water disposal pit and the storm water will be sent to storm water soak pits.



As part of the ESIA, EHC also conducted groundwater quality assessment to establish the baseline. To prevent soil and ground contamination, EHC will install double lining on the evaporation pond and will ensure sound practices to prevent its damage during routine removal of solids. It will also establish continuous monitoring of the groundwater quality.



The water from the collected dredged material at the port will be released back into the sea after being analyzed to ensure it is free of pollutants. The contractor commissioned to complete the dredging is being required to implement the needed measures to reduce turbidity, control actions to avoid soil contamination (i.e., spills, leakages), control air pollution emissions, noise levels, etc.



Hazardous Materials and Hazardous Wastes

Propylene (450 ton/d) is the main hazardous material used at OPC. It is stored in 3 isolated spherical tanks equipped with appropriate cooling, firefighting and leak detection equipment, which can be operated independently for each tank remotely from the control room or locally at the tank.

OPC has a Hazardous Materials Waste Register that is followed during operation to assure appropriate safety measures are being followed.



EHC’s hazardous materials include ammonia (storage tank 20,000 MT); nitric acid (storage tank 7,600 MT); ammonium nitrate (bags 1.2 MT); and diesel (storage tank 70 MT). Ammonia is stored/handled in liquid as well as gas state and ammonium nitrate is stored/ handled in various forms including molten ammonium nitrate in the ammonium nitrate unit, ammonium nitrate stockpiles in the packaging area, and bagged ammonium nitrate stacks in the onsite warehouse.



EHC’s hazardous chemicals will be stored in dedicated and secure locations. All hazardous storage areas will have external and internal signs indicating the class and classification of the substances stored. EHC will implement all needed management and control measures for the proper handling of the ammonium nitrate including storage in well-ventilated buildings; ensuring thorough cleaning of the storage area before the material is transported for storage; placement of the storage area away from flammable materials and sources of heat, fire or explosion (i.e., oil storage, gas pipelines, timber yards, flammable liquids, flammable solids and combustible materials); conducting regular inspections and maintenance of electrical equipment
and fittings; strictly forbidding smoking; and clearly displaying material safety datasheets and safety instructions in the storage area. EHC also incorporated risk mitigation measures in the design of the warehouse and bagging areas to help minimize the likelihood and /or consequences of an ammonium nitrate explosion from chemical contamination, external fire, or high energy impact. Specifically, the warehouse will have explosion resistant walls of 200 mm thick reinforced concrete, it will be maintained at a temperature lower than 32 ˚C, it will have an automatic sprinkler system and proper protection from electrical storms, as well as, CCTV – 24 hour security surveillance and security fencing and gates to prevent access to non-authorized personnel. The 5,000 m3 nitric acid storage tank will be surrounded by an acid resistant surface impounding area to handle releases in case of possible leakage.



The EHC wastes generated during the construction phase are segregated and stored in roll-off containers at waste yards managed by the EPC contractor. Domestic solid waste is stored in waste skips and disposed of in a local landfill. Hazardous wastes generated during the construction (i.e., used lubricating oil, batteries, empty drums of paint/solvent/additives, floor sweepings from material storage yard, oily sludge, contaminated soils from spills, electrical and mechanical components, etc.) are stored in drums and containers at the waste yard established by the EPC contractors, and then transferred to licensed waste treatment contractors.



All EHC operational wastes will be strictly controlled and the waste management plan to be developed will establish the waste management procedures to be implemented to ensure its storage, treatment and disposal in accordance with national legislation and IFC requirements. As part of the waste management plan, EHC will develop a tracking system for the collection, transportation, treatment and disposal of all hazardous waste streams leaving the site location. For the operation phase, EHC will have a dedicated roofed well ventilated hazardous waste area in the downstream wind direction, meeting all relevant fire code requirements, with impervious sloped floor, drainage channel, and sump and pump system. This area will have segregated areas by chemical characteristics; restricted entrance/exit and eyewash and showers. The hazardous wastes will be delivered to the Elnasrya landfill which is a government approved site for delivering hazardous wastes through an approved contractor. It is located in Alexandria at approximately 250 km distant from the plant. The non-hazardous wastes such as wooden pallets and sludge from the water treatment unit will be disposed of at Suez Governorate.



EHC and OPC will implement comprehensive Waste Management Plans for both hazardous and non-hazardous waste ensuring safe storage and timely treatment and/or removal of waste. Copy of these Plans will be submitted to IF
C as indicated in the ESAP.

The port dredged material will be temporarily placed in an onsite impermeable lined disposal basin for drying which is located less than 1 km from the port. The dried material will be finally placed in the Sadat Quarries located within 35 km from the port, or equivalent as per Suez Governorate guidance, as authorized by the EEAA and Suez Governorate. EHC will submit to IFC, as indicated in the ESAP, a copy of the dredged material handling and disposal including the relevant transportation impacts and mitigations.



Noise

The noise sources in OPC are limited to pumps, compressors, etc., thus the impact is localized at the equipment area. It is mandatory to use appropriate PPE to mitigate the impact of potential noise. Upon re-commissioning the plant, OPC will make sure the noise levels are maintained in compliance with Egyptian requirements and WBG EHS Guidelines.



The noise model that was conducted as part of EHC’s ESIA for predicting noise impacts during the operation phase indicated that noise levels at the nearby locations will be acceptable to the Egyptian requirements and WBG EHS Guidelines. EHC will implement measures to reduce noise levels further including installing mufflers/silencers to noise generating machinery and generators to reduce noise levels; placing site noisy equipment (e.g. generators) away from receptors, where possible; installing vehicles exhaust silencers, restricting working hours for particularly loud or intrusive activities, among others. In addition, it will also conduct regular inspection and maintenance of vehicles and equipment. EHC will ensure the noise levels are maintained in compliance with Egyptian and IFC requirements.

Infrastructure and Equipment Design and Safety

CH’s design and operation philosophy is to provide sufficient process safeguards to protect personnel, equipment and the surrounding communities. These include, but are not limited to, the following: smokeless elevated flare; installation of emergency isolation valves, as per design codes; de-pressurization facilities; hazardous emission detectors; protective instrumentation and controls with sufficient redundancy; emergency shutdown instrumentation; emergency alarms; installation of fire protection systems, as per design codes and the neighboring community context; etc.

During construction, OPC conducted a Hazard Analysis and risk assessment and implemented all the associated recommendations. For any later modifications, OPC also conducted HAZOP studies.



As part of the ESIA process, EHC conducted a Quantitative Risk Assessment (QRA) of potential hazards and consequences of accidental impact sources to assess the risk associated with catastrophic incidents (explosion, fire, toxic release etc.). The facilities covered under the QRA included ammonia unloading, storage, and associated equipment at the McDermott Port; the underground ammonia pipeline from the port to the plant; and the nitric acid unit, the ammonium nitrate unit and associated ammonium nitrate. The potential for escalation was also assessed and recommendations provided in relation to detailed layout design including locating main electrical switches, fuses, etc., outside the ammonium nitrate storage areas and others. All the QRA recommendations have been considered and incorporated into the design and/or operations manuals. The results of the QRA after the recommendations ensure that the risk to people or environment is very low, thus acceptable risk from the project. In addition, the EPC contractor as well as a qualified consultant conducted separate HAZOP assessments. Both HAZOP close out reports were issued in 2012 and 2013 respectively.



Mitigation measures for the port operation phase are also being defined including ensuring an efficient weather forecast system to avoid an incident associated with the tankers on the berth during rough adverse sea conditions; establishing prevention measures for berthing, departure maneuvers, unloading of ammonia and propylene tankers (i.e., periodic, regular testing of safety equipment including firefighting inland pumps, firefighting tugs, etc.) In addition, at least two technicians trained on safety and environmental conservation will be available at the berth area 24 hours a day.



For the operation phase, EHC and OPC will develop Emergency Response Plans and Oil Spill Contingency and Prevention Plans. These plans will identify likely emergency scenarios, appropriate response equipment, calibration and maintenance of the equipment, emergency training and drill frequencies, identification of appropriate supporting parties, and communication and coordination protocols with the re
levant authorities, etc. Qualified personnel to respond to any emergency will be available at all times. OPC and EHC will submit to IFC copies of these plans prior to commencement of operations as indicated in the ESAP. Both plants will also become active participants of the already established Emergency Response Mutual Aid Organization established by the industries in the area.



Emergency Preparedness and Response (Communities)

For the operation phase, OPC and EHC will have emergency response plans identifying the operational and natural risks, including the appropriate response, all needed emergency response equipment and qualified trained personnel trained to response to emergencies, among others. In addition, CH will develop a Crisis Management Plan to oversee communication and response of all its industrial operations. A copy of this plan will be submitted to IFC as indicated in the ESAP. Internal emergency plant drills will be conducted on a regular basis. In addition, each plant will also be equipped with its own group of first responders and/or fire brigade to respond quickly and timely to any potential issues that occur on site.



Logistics and Transportation

Logistics and transportation of raw materials and products to and from the CH facilities is a critical component of the operations.



At OPC, propylene, its main raw material, is transported by ship and polypropylene, the product, is transported by truck. The product is packed in bags and OPC has a list of contractors who have received the appropriate induction on polypropylene handling and they have signed Contractors Safety Rules as part of the contractual procedures. The product is either sent to clients in Egypt or exported via Egyptian ports.



At EHC, the ammonia will be transported via ship and truck, the diesel will be supplied via truck and offloaded into storage tanks, and the nitric acid will be also transported by truck from the plant to the customers. EHC is in the process of contracting warehousing at the ports and transport of ammonium nitrate from the plant to the ships for the Alexandria, Adabiya, Port Said Port and Damietta ports. EHC will conduct rigorous assessments to ensure the selected contractors are qualified to store and transport ammonium nitrate. As indicated in the ESAP, EHC will submit to IFC copies of the contractors’ safety capability assessment to store and transport EHC’s product.



OPC will upgrade, as needed, and EHC will develop inland and marine safety transportation/traffic plans including the procedures (trucks/vessels numbers, routes, drivers training, safety inspections, emergency response equipment, etc.) that will apply to their own operations as well as those of its contractors. Copy of the safety transportation/traffic plans for both OPC and EHC will be submitted to IFC as indicated in the ESAP.



Product Stewardship

OPC is registered with REACH and EHC is awaiting production to gain registration. REACH is
the Regulation on Registration, Evaluation, Authorization and Restriction of Chemicals which entered into force on June 2007 and streamlines and improves the former legislative framework on chemicals of the European Union (EU).



Security Personnel

OPC and EHC will employ non-armed private security personnel from specialized firms in the sector. Security personnel are screened for criminal backgrounds and are provided with training in the use of force. The plants do not rely on Egyptian public armed forces for any services or support. CH implements security policies and procedures commensurate to the operations’ risks and provides security personnel codes of conduct and training to ensure appropriate conduct with neighboring communities. Copy of the security procedures for both OPC and EHC will be submitted to IFC as indicated in the ESAP.

Client’s Community Engagement
CH will develop a corporate policy to ensure focused stakeholder engagement. Engagement with communities at the local level is generally managed at plant level. Interaction with communities is relatively limited given that CH’s operations are situated in an industrial area with limited community presence nearby. Engagement with communities has been limited to the implementation of community based projects such as the building of two Schools in Suez, support of the local sporting club in Suez, sponsoring local martial art competitions for children, providing medical equipment for the Suez hospital among others. A grievance mechanism for the community will be developed and shared with local communities, in alignment with IFC PS 1 requirements.

CH will disclose this document in Arabic language in the communities where plants are located. Shortly after publication in IFC’s website, the document will be displayed at the following locations:

1-     Suez Governorate Secretary General, Suez Governorate Building, Suez, Egypt.
2-     Egyptian Environmental Affairs Agency Regional Branch Office in Suez Governorate, Suez, Egypt.

OPC
Omar Yousef
Manager, HSE
Oriental Petrochemical Co. (OPC)
Suez, Sokhna road, KM 35
P.O.Box 83 El Suez Egypt.
Tel: +20-62 3420008/9
Fax:+20-62 3420003 

EHC
Said Yehia
Head of Section, HSE
Egypt Hydrocarbon Corporation
Ninth Industrial Zone
Northwest Gulf of Suez
Ain Sukhna, Suez
Egypt
Tel: +20 (62) 3393-700
Fax: +20 (62) 3393-800

Broad Community Support is not applicable for this project

Title	Anticipated completion Date	Status	Comments	Completion Date
1. Provide evidence of development and implementation of the Environmental, Health, Safety (EHS) and Social Management System for Carbon Holdings at the corporate level aligned with the requirements for such as defined in the Environmental and Social Review Summary document	03/31/2015 12:00:00 AM	Completed	Completed	01/31/2016 12:00:00 AM
2. EHC to develop, implement and provide to IFC with a copy of operational environmental, health and safety procedures by EHC listed in the ESIA, as well as these listed below: a. Environmental Monitoring Plan for ambient air conditions, stack emissions, liquid effluents, workplace conditions (including sampling collection, parameters, frequencies, analysis methods, performance indicators) and others, b. Occupational Health and Safety (work related statistics, training, operational accidents, etc.), c. Training Plan, d. Preventive Maintenance Plan, and e. Stakeholder Engagement Plan, etc.	03/31/2015 12:00:00 AM	Completed	Completed	04/30/2015 12:00:00 AM
3. Develop, implement and provide to IFC with a copy of a Community Grievance Mechanism aligned with the requirements of the Performance Standards for Carbon Holdings to be applied to all its operations.	05/31/2015 12:00:00 AM	Completed	Completed	01/31/2016 12:00:00 AM
4. Develop, implement and provide to IFC with a copy of the procedure used to inform employees about the Employees Grievance Mechanism.	05/31/2015 12:00:00 AM	Completed	Completed	01/31/2016 12:00:00 AM
5. Develop, implement and provide to IFC with a copy of a Waste Management Plans for both OPC and EHC.	07/31/2015 12:00:00 AM	Completed	Completed	04/30/2015 12:00:00 AM
6. Develop, implement and provide to IFC with a copy of Port Dredged Material Handling, Transport, and Disposal Procedures	03/31/2015 12:00:00 AM	Completed	Completed	01/31/2016 12:00:00 AM
7. Develop, implement and provide to IFC with a copy of OPC and EHC Emergency Response Plan and Oil Spill Contingency and Prevention Plans for both plant and port operations	05/31/2015 12:00:00 AM	Completed	Completed	01/31/2016 12:00:00 AM
8. Develop, implement and provide to IFC with a copy of an Emergency Response Procedure for the transportation of the mining grade ammonium nitrate from the site to the port	05/31/2015 12:00:00 AM	Completed	Completed	02/28/2016 12:00:00 AM
9. Develop, implement and provide to IFC with a copy of a Crisis Management Plan for Carbon Holdings to be applied to all its operations	07/31/2015 12:00:00 AM	Completed	Completed	01/31/2016 12:00:00 AM
10. Develop, implement and provide to IFC with a copy of an EHC’s contractors’ safety capability assessment to store and transport ammonium nitrate that is acceptable to IFC	07/31/2015 12:00:00 AM	Completed	Completed	04/30/2015 12:00:00 AM
11. Develop, implement and provide to IFC with a copy of a security procedures for OPC and EHC aligned with the requirements of the IFC Performance Standards.	05/31/2015 12:00:00 AM	Completed	Completed	04/30/2015 12:00:00 AM