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

This proposed project is classified as Category B according to IFC’s Environmental and Social Review Procedure as the environmental and social impacts of the projects are limited, site-specific and can be minimized, avoided or mitigated by adhering to generally recognized performance standards, guidelines, or design criteria. Key environmental and social issues associated with this project include managing Occupational Health and Safety (OHS) risks; operational hazards from handling hazardous materials; and emergency response and fire protection.

The project is located in Sokhna port (an existing, operational facility) and is surrounded by industrial activities. As per existing information, the pipelines right of way will not involve displacement activities. Thus, PS 5 is not considered applicable to this project. The project location is in a brownfield area currently devoid of important or threatened species and accordingly PS 6: Biodiversity Conservation and Sustainable Management of Living Natural Resources does not apply. Indigenous Peoples were not identified in the project area and no issues related to cultural heritage were identified in the project area; thus PS7: Indigenous Peoples and PS8: Cultural Heritage is not applicable.

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

Environmental and Social Assessment and Management System

An Environmental and Social Impact Assessment (ESIA) for the development of the LBT was initially prepared in 2011 and updated in 2014, and an Environmental Impact Assessment (EIA) was prepared in 2014 for widening Basin 3 and receiving LNG. Both studies have been approved by the Egyptian Environmental Affairs Agency (EEAA). In addition, an EIA was developed for the dredging of basin 3 in 2007, and an EIA for the ammonia plant covering the marine component in 2003. Approvals for both studies were obtained from EEAA.



The scope of the ESIA conducted for the LBT terminal covered the pipelines connecting the tank farm to the jetty loading arms, but did not cover the Gasoil and LPG pipelines connecting the tank farm to the existing national grid outside the port fence. Construction of the pipelines sections is part of the works under the EPC contract. As set forth in the ESAP action # 1, Sonker will ensure that an ESIA has been developed for the pipelines prior to construction. The exact location of the pipeline Right-of-Way will be confirmed and land take will need to comply with IFC Performance Standards 5 on Land Acquisition and Involuntary Resettlement.

In order to ensure that the cumulative risks and impacts of the different components of the terminal are taken into consideration, a cumulative impact assessment will be carried out as an annex to the ESIA, as set forth in ESAP action #2. This assessment will cover the cumulative ambient air quality and safety risks and any additional identified risks for the different components of the project as well as the ammonia operations and operations in the vicinity of the terminal.



Sonker is still at an early stage of developing its Environmental and Social Management System (ESMS) and Occupational and Health and Safety (OHS) system. As set forth in ESAP action #3, the company will develop and implement E&S and OHS management systems allied to the Performance Standards and applicable World Bank Group (WBG) EHS Guidelines.



Policy

Sonker has developed as set of EHS policies that were all effective as of December 2014. These policies include the HSSE policy, with the objective to promote the highest practicable standards of health, safety, security, and environment management for Sonker Bunkering Company and to ensure compliance with the Egyptian laws and associated regulations, standards and codes of practice for ensuring work health, safety, security, and respect for the environment.



Sonker has also developed an ESIA Policy to ensure that Sonker identifies environmental and social impacts at an early stage of the project development, and scopes the appropriate studies to assess, and where necessary, mitigate those impacts.



In addition, Sonker has also developed the fundamentals for a safety policy which sets the necessary direction and support to ensure Sonker meets its responsibility and accountabilities under the requirements
of the Egyptian work health and safety legislation and associated regulations, and to provide clear guidelines for all Sonker employees, suppliers, partners and others in meeting their legal obligations.



Identification of Risks and Impacts



Within the scope of the LBT ESIA, a Quantitative Risk Assessment (QRA) has been developed. The QRA addresses mainly acute, rather than chronic, hazards. It is based on rare but potentially hazardous incidents which could result in fatalities and/or severe injuries for workers and people outside of the site boundary. The study indicated that the individual risks for workers resulting for the different scenarios adopted in the study is as low as reasonably practicable (ALARP) and the acceptable risk regions.



In addition, the study recommended risk reduction measures in order to keep risks within acceptable limits. These measures include developing a comprehensive Emergency Response Plan (ERP) including effective means for detection of gas/liquid leaks as well as means for escape, evacuation and rescue; establishment of an effective communication channel between different units in the facility and the central control room as well as the neighboring companies and the local civil protection authorities to ensure prompt action during emergency situations; regular inspection of the fire and gas detection and alarm systems; regular inspection of the escape, evacuation and rescue system; and periodic escape and evacuation drills.



A QRA has also been developed for the ammonia operations within the port. As per ESAP action #4 a QRA for the worst case scenario with impact radius will be developed for all storage tanks (ammonia, LPG, gasoline, etc.). QRA results will be used in the project designs and site EHS management.



The risk and impacts on biodiversity in the project area have been assessed through studies carried out within the scope of the ESIA. A scuba diving survey indicated the absence of sensitive habitats within the boundaries of the study area, such as coral reefs or sea grass. This is due to the high turbidity of the water caused by the fine-grained landfill sediment covering the seabed.



Studies have also concluded that the project location and its hinterland (within the port premises) are devoid of important or threatened species. The area has experienced intensive anthropogenic changes due to the establishment of the port and numerous industrial facilities in the surrounding areas. However, the whole Sokhna area is an important route for migratory birds. Sokhna is included among the Important Bird Areas (IBAs) of Egypt according to a set of criteria developed by BirdLife International Secretariat. However, after construction of the port and its surrounding activities these birds have moved to other nearby locations.



The risks associated with maneuvering of ships in the terminal has been assessed through conducting an LNG tanker maneuvering simulation. The simulation confirmed that t
he basin width after widening is sufficient. It also confirmed that the design of the berth is optimal as the prevailing wind directions are limiting the influence of wind to the lateral windage area of the LNG tanker. The study also identified a number of recommendations which Sonker is committed to implement, including installation of additional leading lights on the shores of the turning area, training of pilots and tug masters in standard maneuvers, establishment of communication and emergency procedures, and strict adherence to standard maneuvers to be described in guidance to masters and pilots.



In addition, another simulation was carried out to assess whether Azimuth Stern Drive (ASD) tugs would be suitable to undertake all towage requirements. The ASD tugs are equipped with two stern engines capable of generating a 360°, all directional propulsion force. The simulation considered arrival and departure scenarios with 4 attendant tugs. Differing environmental and wind conditions were trialed as well as emergency maneuvers simulating a rudder lock on the LNG Carrier at varying speeds. All trials proved that, operated correctly, the ASD tugs were capable of controlling the LNG carrier. The simulation results indicated that the LNG terminal within basin 3 provides significant challenges to pilots and tug masters and it was recommended that suitable training be provided to all tug masters and pilots with regards to effective port ASD tug operations. These trainings were performed in April 2015.



Organizational Capacity and Competency

Sonker currently has a limited number of employees and relies on the Amiral team. In the terminal, there are currently 20 workers including a terminal manager. These are all DP World employees and their affiliation will move to Sonker starting May 2015. The Terminal Manager responsibilities include oversight of the LNG operations, ammonia operations, maintenance, health, safety, environment and security. The terminal manager reports directly to the Sonker managing director.



Sonker is planning to restructure its organization and will contract Operations and Maintenance (O&M) to a professional international contractor. The O&M contractor will also have the responsibility for Health, Safety, Security, Environment and Quality (HSSEQ). The HSSE and the O&M contractor will report to Sonker’s managing director. Sonker is currently negotiating with the potential contractor with the plan to start the contract in September 2015. The contractor will be responsible for training Sonker employees in Egypt and abroad.



Emergency Preparedness and Response

Sonker developed a preliminary emergency plan for the ammonia storage and the jetty. This plan is pending alignment with the FSRU emergency plan developed by Hoegh. As set forth in ESAP action #5, Sonker will develop an emergency preparedness and response plan covering the different operations in the terminal and aligning with the different parties including EGA
S and Hoegh for the FSRU, and EBIC for the ammonia storage and handling.



Fire hazard and chemical release are the main operational risks at Sonker’s terminal and the company will have strict management procedures to control fire hazard and prevent chemical leak. Personal electronics are not allowed in the storage and jetty area. As set forth in ESAP action # 6, Sonker will install fire and gas sensors, and instruments for detection of temperature, smoke, and chemical concentrations at all high risk areas. The sensor systems will be connected with the central control room at the terminal.



Sonker has installed both fresh water and sea water firefighting systems and conducts a firefighting drill every three month. As set forth in ESAP action # 7 Sonker will align with the FSRU team in terms of emergency response management and will conduct joint emergency response drills.



Monitoring and Review

Within the scope of the LBT ESIA, an environmental monitoring plan has been developed covering both construction and operation. Sonker will review and starting implementing the monitoring plan. Sonker will keep an environmental register covering monitoring results, resource consumption, OHS monitoring such as incidents, accidents, and near misses. As set forth in ESAP action # 8, Sonker will also commission periodic EHS audits by an independent EHS consultant.



Stakeholder Engagement

Within the scope of the ESIA carried out at project inception scoping and disclosure consultation meetings were held where representatives from regulatory bodies, the neighboring activities and the local Bedouin community in the general vicinity attended.

The project is located in brownfield industrial port zone not in the vicinity of a community. According, continuous community engagement and consultation is not required. However, Sonker will develop and implement a grievance mechanism to receive and investigate complains related to the environmental and social performance of the project.

Working Conditions and Management of Workers Relation

Employees currently working in the project terminal are DP World employees. Their contracts will change from DP World to Sonker in May 2015. The planned number of employees of Sonker for the operational stage is around 50, 20 of whom are already working under DP World contracts.



Sonker will adopt the same hiring procedures as Amiral where all workers have contracts and senior management have open ended contracts. All workers have medical insurance through a private company. Currently transportation is provided to onsite workers. For office staff, non-technical staff and technical staff, the daily working hours is 9 hours including lunch break. For shift staff the company fixes a separate working schedule for shift duties, subject to the nature of work. Each shift crew works 4 days on and 4 days off. Shifts on duty are working as the pre design working schedule which is 12 hours per day.



Human Resources Policy and Management

Sonker has developed HR policies including a hiring policy, compensation, benefits, and leave, medical insurance and life insurance, and a termination policy. The HR polices also include a conflict of Interest and Business Conduct Policy which covers harassment. Security and Industrial Safety is also covered in the HR polices.



As set forth in ESAP action # 9, the company will revise the HR policy in line with PS2 requirements to cover non-discrimination and equal opportunity, a worker grievance mechanism covering staff and contractors, employee appraisals, workers organization, OHS, and training and development.



Workers Organization

There are no worker unions in the company and workers have not requested to join unions. The company management does not prevent workers from joining unions though and national legislation allows for such.



Grievance Mechanism

As per Sonker HR policies, the company adopts an open door policy for grievances, when an employee has a problem the company encourages her/him to approach her/his direct manager for discussion. In case the employee is dissatisfied with the feedback to her/his concerns, she/he can contact the higher level in her/his division for a satisfactory answer to her/his concerns. If an adequate solution has not been reached, then the employee can approach Administration Department for final answers to his concerns. The new grievance mechanism mentioned above under the revised HR Policy will include provision for anonymous grievances to be raised and addressed, and will ensure that employees and contractors are made aware of the availability of the grievance mechanism and that it is easily accessible.

Protecting the Work Force:

There is no child or forced labor in Sonker. The company also checks the contractors to make sure that all the contracted labors are at least 18 years old.



Occupational Health and Safety

There is sufficient personal protective equipment (PPE) at each position and workers observed on
site during IFC’s visit were all wearing proper PPE. The workers receive periodical training on OHS from the terminal manager. As mentioned above, given the OHS risks associated with the construction phase, Sonker will develop an OHS management system for construction operations to be followed by Sonker and all its contractors and subcontractors, as set forth in ESAP action #10



Workers Engaged by Third Parties

The Engineering, Procurement, Construction (EPC) contract has been awarded to Petrojet, which is 97% owned by EGPC. Petrojet, is certified against ISO 14001 for environmental management system and have a track record of 74 million safe man hours in 2014. The contract with Petrojet is still being finalized. Sonker will ensure that the EPC contractor follows the Performance Standards and the World Bank Group (WBG) EHS Guidelines and that all subcontractor are required to comply with the company’s OHS procedures and practices (including training requirements) and will have access to either the company’s grievance mechanism to be developed, or that associated with the contracting company. These requirements will also apply to the O&M contractor.



The FSRU have a team of 30 persons onboard from the operating company Hoegh. The vessel will operate 365 days per year on a 24 hour basis. All critical functions would be manned 24 hours per day utilizing a three shift process, each totaling 8 hours daily. Other functions would be accomplished on a regular, scheduled basis. Crew changes would take place at the port. In total about 60 persons shall be contracted to the FRSU annually. The vessel shall meet the requirements recommendations of International Labor Organization (ILO) Code of Practice on Safety and Health in Dock Work, 1977, and Maritime Labor Convention 2006.

Resource Efficiency

There are no manufacturing processes at this project. Seawater will be used for all cooling purposes and will be discharged back to the sea. Seawater will also be used for fire water, water curtain, and ballast and cooling of engines and auxiliary machinery systems. In the FSRU cooling water for the used for the engines (heated water) will in normal operation directed to the regasification cycle, reducing the overall water consumption instead of directly discharging to the sea.



Electricity consumption in the terminal is obtained from the grid and it is mainly used for operation of pumps and for lighting. Sonker will ensure full back-up for electricity through standby generators. The FSRU uses its own electrical power sources for operation of pumps and equipment for the regasification process, for auxiliary systems and for the accommodation. The generators will be driven by dual fuel diesel engines using Boil Off Gas (BOG) as the main fuel. A small amount of Marine Diesel Oil (MDO) is also required as pilot fuel in the engines.



Air emission and ambient air quality

Air emissions from the operation of the terminal will result from emissions from loading and unloading operations. When loading/unloading a ship with liquefied gas, the vapors from the ship will be recovered via a vapor balancing system. This system consists of vapor piping works connecting the vapour spaces of the ship and the storage tank.



Fugitive emissions are also expected from the tank farm, resulting from the seals, tank breathing, cleaning, and blanketing. There is no fugitive emissions recovery system installed as the expected emissions are limited. Sonker will monitor the fugitive emissions to ensure that it is within the regulatory acceptable limits.



A flare will be utilized for safe discharge of gases only in major emergency situations, which include interruption of the cooling system. Boil off gases will be guided to the flare for controlled burning.



Hazardous Materials

The handling, storage, and transportation of the ammonia, LPG, LNG and gasoline in the terminal could pose serious dangers to the employees and nearby industries if not well managed.

Sonker has started developing a Hazard and Operability Analysis (HAZOP) study. The first step included review of the marine activity and the process steps of ammonia loading at basin 3 in order to ensure safe operations and operational effectiveness. A three day HAZOP workshop was carried out in March 2015. Representatives from Sonker, EGAS, GASCO, Hoegh LNG, various LNGC carriers, and DP world attended the workshop. The workshop covered Marine HAZOP to identify the hazards, safeguards in place and potential recommendations for the marine activities related to LNGC, FSRU and ammonia vessel. It also covered process operation HAZOP to identify the hazards, safeguard in place and potential recommendations for the ammonia recirculation and loading activities. The workshop resulted in a set
of actions with responsibilities identified and due dates for carrying out the task in relations to the action. The study concluded that no major issues or showstoppers were identified. As set forth in ESAP action # 11, Sonker will develop HAZOP studies for all the handling processes and will be updated if these processes are modified and/or updated.



Wastewater Treatment

Domestic waste water from the administration office (maximum 35 persons simultaneously; 3m3/day) will be treated with a small portable waste water treatment station. The effluent will be used for irrigation purposes.



The terminal will not be receiving wastewater from ships. In case vessels are in direct need to be relieved of waste water, they will be given the opportunity to move to basin 1 area, where on board waste water tanks can be emptied to trucks, which then can dispose of the bilge water at governmental approved waste water treatment plants.



The FRSU carrier is equipped with a sewage treatment unit sized to suit the FRSU carrier living accommodations capacity. While at the port, the discharge from the sewage treatment unit and other accommodation drains will be collected in a tank for later disposal to shore, in accordance with local regulations.



Spent oils from equipment are expected to be generated. These will be disposed of through a licensed contractor (Petrotrade) for recycling.



GHG Emissions

After this project is implemented, the Terminal project will generate approximately 61,600 tonnes of CO2-equivalent annually, mainly from natural gas consumption at the FSRU turbine.

Community Health and Safety

The activities surrounding the port are industrial activities. The closest community is a Bedouin settlement over 6 km to the southwest of the project location, and a tourism resort approximately 3 km north of the project location. The normal operations at the jetty and pipeline will have no impacts on communities.



Security Personnel

Security of the port and the basins are provided by DPW, the Egyptian Armed Forces and police. In addition, Sonker has assigned a private security company, Falcon, for basin 3. Falcon security guards are unarmed as per the port policies. As noted above, there are no neighboring communities to the port, hence interaction between community members and security guards is not anticipated.

Clients Community Engagement
Being located in the brownfield industrial port zone, Sonker project facility is not located in close proximity of settlements. The project’s main external stakeholders are the industrial establishments in the surrounding area, the tourist resort 3 km away and a distant (6 km away) Bedouin settlement. As such, the project does not have directly affected communities.

Sonker will develop an external communication mechanism which allows the external stakeholders to raise their concerns.

The ESRS and the ESAP will be translated into local language and be available at the company premises allied to being published in the company website.

For more information, enquiries and comment please contact:
Mr. Paul van der Wilden
Chief Financial OfficerAmiral Group29 Farid Street, HeliopolisCairoEgypt

Broad Community Support is not applicable for this project

Sonker(36828) Supervision Disclosure Snapshot – Version 2
Description	Anticipated Completion Date	Status	Comments	Completion Date
Ensure that an ESIA and ESMP is developed for the pipelines prior to construction and that, should any economic or physical displacement be necessary, land acquisition and/or resettlement is implemented according to IFC PS 5 requirements (including preparation of appropriate documentation)	30-Sep-2015	Completed	Completed	9/30/2016
Develop a cumulative impact assessment as an annex to the BLT ESIA, covering the risks of the different components of the project as well as the ammonia operations, and operations in the vicinity of the terminal	30-Sep-2015	Completed	Completed	4/7/2019
Develop and implement environmental and occupational health and safety management systems that incorporate the existing procedures and are consistent with the IFC Performance Standard 1 and the World Bank Group (WBG) Environmental Health and Safety (EHS) Guidelines. These systems are to include management procedures, monitoring plans and KPIs for environmental and OHS parameters and reporting requirements for such to ensure senior management are regularly informed of the status quo.	31-Dec-2015	Completed	Completed	3/30/2019
Develop QRA for the worst case scenario with impact radius is required for all storage tanks (ammonia, LPG, gasoline, etc.)	30-Sep-2015	Completed	Completed	10/31/2017
Develop an emergency preparedness and response plan covering the different operations in the terminal and aligning with the different parties including EGAS and Hoegh for the FSRU and EBIC for the ammonia storage and handling.	30-Sep-2015	Completed	Completed	11/28/2016
Install gas sensors, and detection of temperature, smoke, and chemical concentrations at all high risk areas. The sensor systems will be connected with the central control room at the facility	31-Mar-2017	Completed	Completed	12/31/2020
Alignment of an emergency response management with the FSRU and conduct at least one joint emergency response drill.	15-Jun-2015	Completed	Completed	12/31/2018
Commission periodic EHS audit by an independent consultant. The first one to be carried out in 2015	31-Dec-2015	Completed	Completed	4/7/2019
Update the human resource policies and procedures to align with PS2 requirements and more specifically ensure compliance in respect of requirements related to non-discrimination and equal opportunity, grievance mechanism, hiring process, and employee’ appraisals.	30-Sep-2015	Completed	Completed	12/31/2022
Develop OHS management system for construction operations	30-Sep-2015	Completed	Completed	11/28/2016
Develop HAZOP studies for all the handling processes and will be updated if process is modified and updated	31-Dec-2015	Completed	Completed	11/28/2016