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
PS 5 – Land Acquisition and Involuntary Resettlement
PS 6 – Biodiversity Conservation and Sustainable Management of Living Natural Resources
If IFC’s investment proceeds, IFC will periodically review the the project’s ongoing compliance with the Performance Standards
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 Peoples is not considered applicable. Archaeological and historic sites were not found within the project site’s boundaries, thus PS8 - Cultural Heritage will not apply.

Key environmental and social impacts associated with this type of operation include air emissions, liquid effluents, noise and hydrocarbon vapor exposure, handling of hazardous materials, transportation, land and marine biodiversity, and community related impacts and risks.

The proposed project is Category A per IFC’s Environmental and Social Sustainability Policy (2012): although it is expected to bring economic and social benefits it will be a source of significant, diverse and irreversible impacts during the construction and operational phases as discussed below.

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.

To comply with Panamanian regulatory requirements and as part of the project permitting process, AES commissioned URS Holdings, Inc., a multidisciplinary consultant firm, to prepare and ESIA for the LNG terminal, the power plant and its associated operations, as well as the dredging activities. The ESIA cover potential impacts and risks for the entire project life-cycle from site preparation, construction, operation and decommissioning as well as assessment of the potential cumulative impacts within the project area. The company received the environmental permit from the Ministry of Environment, the Panamanian environmental authorities, for the ESIA in February 24th, 2016.



AES commissioned an update of the ESIAs, resulting in a comprehensive Environmental and Social Impact Assessment (ESIA) to conform to international standards and the IFC PSs, which was completed in March 2016 and is attached to this summary. The ESIA covers potential impacts and risks for the entire project life-cycle from site preparation, construction, operation and decommissioning as well as assessment of the potential cumulative impacts of all local industry on its area of influence. The ESIA includes frameworks for the Environmental and Social Management Plans (ESMPs), to be implemented at the various phases of the project, preventing and addressing key impacts as well as monitoring arrangements. Key environmental plans include management of hazardous wastes, air emissions, liquid effluent treatment, erosion control, occupational health and industrial safety, emergency response plans, flora and fauna rescue and relocation, dredging, and biodiversity management. The Social Management Plan being developed aims at mitigating adverse project impacts and supporting long-term socioeconomic development in the surrounding District of Colon. The plan includes a policy framework, community health measures, participatory monitoring plan, a local hiring plan, stakeholder engagement plan, security management plan, as well as implementation arrangements, including grievance redress for workers and communities and monitoring mechanisms.



The ESIA presents the process followed by the company for the selection of the project site and the selection process aiming to pose minimum social and environmental impacts. Key aspects considered in the selection included avoidance of community relocation and minimum disturbance to natural areas, among others.



As part of the E&S assessment of the project, the company commissioned baseline and assessment studies including: biodiversity (flora, fauna), hydrology (assessing flooding risks, precipitation regimes, etc.), ambient air and noise baselines, and soil contamination. As part of the assessment, the company also commissioned studies to assess the likelihood and risks of hurricanes, tornados, cyclones and earthquakes in the study area. The assessment demonstrated that the geographic location of the site (Limón Bay) has sheltered th
is region from the negative impacts of hurricanes in the past. Thus, anticipated climate change impacts from an increase in the number and strength of hurricanes in the project site are not anticipated. The results also revealed that the study area is not prone to tornados, cyclones, or earthquakes.



As part of the ESIA, the company also conducted a cumulative impact assessment (CIA). It identified value components (VECs), covering physical, marine and social aspects. Identified possible future projects include works of electric generation (a thermoelectric plant and electricity generation barges), works related to port activity (dredging and construction of a pier), expansion of farm tanks, renovation works and urban improvement, and a power transmission line. The analysis of the contributions of each of these projects to the occurrence of cumulative impacts in the environment of the project, indicates that the construction of a thermoelectric plant close to the same, would affect the greatest number of VECs on air quality, water quality, and noise. The CIA also presents actions that should be taken in case these projects materialized, such as promote intercompany agreements to evaluate and implement best practices to prevent and control potential impacts, establish continuous monitoring system to assess the quality of the environmental conditions, establish interinstitutional coordination to discuss and establish best practices, among others,



To support the ESIA, socio-economic baseline information in the project’s area of influence was also gathered and recorded. This data was gathered through household interviews and questionnaires as well as during the community consultation events carried out in communities and towns in the areas of influence.



The EPC contractor will be required to develop and implement detailed environmental pollution control and occupation health and safety measures based on project ESMPs.



Policy

AES has a corporate environmental, health, safety, and social policy that is implemented in its projects across its operations. Thus, this project will specifically adopt the corporate policy which will be reflected in all programs/procedures and systems to be implemented.



Management Programs

Key to the construction phase will be the environmental, health, safety (EHS) and social management and monitoring program to be established by the engineering, procurement, and construction (EPC) contractor selected by AES. The responsibility for compliance with the ESIA findings including EHS and social management commitments and management planning are being included in the EPC contract agreements.



Alignment of the EPC contractor with project requirements will be closely managed and monitored by AES through contractor management plans and procedures to be developed by the company and to be submitted to IFC as indicated in ESAP action # 7 to ensure that the control and mitigation measures are being implemen
ted in accordance with AES’s EHS and Social commitments with the IFC PSs.



POSCO Engineering & Construction Company, the EPC contractor selected for the construction of the plant and terminal has demonstrated international experience in the design and construction of similar projects. This contractor is required to operate an environmental management system in accordance with the international ISO 14001 and OSHAS 18001 standard requirements and to develop detailed project EHS Management Plans (ESMPs) which will be submitted to the sponsors and IFC as indicated in ESAP action # 8. The ESMPs will include procedures for environmental management, traffic management, dust management, occupational health and safety, dredging, labor conditions, community engagement, grievance mechanisms, biodiversity rescue/removal/restoration, etc. Further to this, the EPC contractor will give preference to directly and indirectly affected communities for employment. In addition, the EPC contractor will have an EHS organization consisting of a team of EHS and Social professionals on-site throughout the construction phase. AES will directly handle the relationship and engagement with the communities.



For project operations the company will establish and implement an Environmental, Health, Safety, and Social Management System (ESMS) based on the Panamanian regulations and AES’s own Corporate ESMS; IFC’s PSs; the relevant WBG EHS Guidelines; and internationally recognized EHS and social standards (i.e. ISO 14000 and OHSAS 18000.) The ESMS 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 a stakeholder engagement program. The management program for operations will be developed before the start of AES facility operations and submitted to IFC, as per ESAP action # 16.



Organizational Capacity and Competency

The company has three Environment and Social (E&S) teams: i) Environmental Compliance, ii) Health and Safety / Security, and iii) Community Relations. Each team has a Manager and a number of specialist support staff. Environmental Compliance and EHS Managers reports to the Construction Director. Community Relations Manager reports directly to the Project General Manager. In addition to the trained specialists in environmental and H&S aspects already in place, the company is hiring additional qualified personnel. These teams are responsible for managing the health, safety, environmental and social programs, environmental and social awareness and training, health and safety training, overseeing of the EHS and social performance of the contractors, ensuring regulatory compliance, implementation of compliance audits, stakeholder engagement, grievance management and documentation, and E&S monitoring and record keeping, among others.



Emergency Preparedness
and Response

For the construction phase, the EPC contractor will be required to develop and implement an Emergency Response Plan and have qualified personnel and equipment response to potential emergencies as part of its EMP. Potential emergency scenarios will also be identified by AES in conjunction with the EPC contractor and adequate emergency response arrangements will be developed for implementation. This will include provisions for a trained and equipped emergency response team to be ready to respond to emergency events.



For the operation phase, AES will develop an Emergency Response Plan for onsite as well as offsite operations considering appropriate emergency preparedness and response measures to implement in the event of a fire, leak, spill, etc. This plan will identify likely emergency scenarios, appropriate response equipment, response equipment, emergency training and drill frequencies, identification of appropriate supporting parties, etc. Qualified personnel to respond to any emergency will be available at all times. The company will submit a copy of this plan prior to operations to IFC as indicated in ESAP action # 20. In addition, SINAPROC, the local entity regulating these actions has been already informed on the project and will provide recommendations for this plan and coordination with projects in the vicinity.



Similarly, as part of the emergency response procedures, the emergency response plan to be developed for each of the project phases will include the communication to and training of the communities related to response to emergencies. As part of its emergency response planning, the company will also involve the local authorities in the development of community preparedness planning in the event of a major accident.



Monitoring and Review

As part of the implementation of the project, the company will develop the monitoring plans frameworks included in the ESIAs, for the construction and operation phases respectively covering aspects such as air emissions, air quality, liquid effluents, noise, water quality, workplace conditions, biodiversity, social aspects, water and energy consumption, GHG emissions, etc., as indicated in the ESAP actions # 9 and 15 respectively. The EPC contractors will develop the monitoring plan for the construction phase and in turn, AES will develop the corresponding monitoring procedures to oversee their EHS performance. AES will implement the expected EHS & social measures and continue to assess E&S performance during the operational phase. For all phases of the project, the company will commission an independent third party environmental and social audit of its operations to confirm compliance with Panamanian legislation and IFC PSs.



AES is committed to periodically report the results of its environmental and social performance to the Panamanian environmental authorities, IFC, other international lenders, and nearby communities based on its own and third party performance as
sessment.

Human Resources Policies and Procedures

AES corporate human resources policies and procedures are rooted in the values that guide their actions with staff, partners and suppliers, customers and the many communities and environments in which they operate around the world. These values are: i) Put Safety First; ii) Act with Integrity; iii) Honor Commitments; iv) Strive for Excellence; and v) Have Fun through Work.



These values provide a common framework for business decisions, actions, and behaviors at all AES operations. For this, as AES does it for other projects, the company hired and train qualified Human Resources (HR) personnel to manage its HR policy and its procedural elements for the project, support the construction management team (CMT) with the implementation of the HR and E&S policies, standards and procedures, and coordinate all HR activities between the EPC contractor and the CMT.



The project promotes transparent application of their labor policy through a series of measures including external labor assessments and audits, the creation of worker’s grievance mechanism, and a campaign to broadly communicate the company’s policies on anti-discrimination and local hiring practices and grievance mechanisms. They also have zero tolerance for discrimination or harassment.



The EPC contractor will develop an HR policy which ought to be aligned with the company’s HR policy. Copies of this HR policy will be submitted to IFC as per ESAP action # 10.



Working Conditions and Management of Worker Relationship

During the construction phase, the EPC contractor is committed through the contractual agreements to ensure that labor conditions comply with the requirements of Panamanian legislation and IFC Performance Standard 2. The company will develop a plan to monitor the performance of the EPC contractor to ensure that labor conditions are in compliance with the contractual requirements. Monitoring will include regular audits, review of the EPC contractor internal monitoring reports and documentation as well as review of grievances logged by the contractors and subcontractors employees.



The company expects the peak workforce during construction to reach about 1500 to 2000 direct positions and until 3000 indirect jobs for both combined, the CCGT and the LNG terminal. Operations will require up to 60 direct workers and approximately 200 indirect workers.



A Local Hiring Plan will be developed and implemented jointly with the EPC contractor. This plan will ensure prioritization for employment of members of the nearby communities and will include an assessment of availability of workers in order to determine potential influx impacts. As part of the contract, the EPC contractor is being required to guarantee that at least 60% of the professional workforce will be contracted in Panama.



For purposes of workers’ accommodations, the EPC contractor will need to consider suitable accommodations in nearby communities for those workers
who do not already live in these communities. As part of the EPC ESMS as indicated in ESAP action #8, and as required by the company, the EPC contractor will develop a Workers’ Accommodation Management Plan outlining the expected quality of workers’ accommodation and the way they will be monitored to ensure high levels of safety and health among workers and local communities.



Working Conditions and Terms of Employment

The terms of employment are defined in the internal employment rules and regulations (reglamento interno de trabajo and collective labor agreement) and are provided to each employee when contracted where benefits, hours of work and overtime compensation, among others are defined, and in the individual work contracts where their wages are defined. AES employees receive life insurance (100% paid by the company), health insurance (70% paid by the company if an employee have dependents or 100% paid by company if an employees do not have dependents). The conditions for the EPC contractor employees will be defined in the EPC Contractor’s HR policy to be delivered to IFC according to action #10 of the ESAP.



Workers’ Organization

AES corporate policies guarantee all workers, including those hired by the EPC contractor, the right to form labor organizations or associate with any existing ones.



Panama is a member of the International Labor Organization (ILO). As such, it is committed to adopt and maintain in law and practice the rights as stated in the 1998 ILO Declaration on Fundamental Principles and Rights at Work and it’s Follow-Up. These include pledges to provide access to judicial tribunals for labor law enforcement; ensure that the enforcement process is fair, equitable, and transparent; and promote public awareness of their labor laws. Panama’s current laws and practices related to internationally recognized labor rights are considered largely consistent with relevant international standards. For example, the Constitution of Panama and the Labor Code provide workers and employers with the right to form unions for economic and social activities, bar discrimination on the basis of a worker’s union-related activities, and establish the right to strike. The Labor Code provides for the right to collective bargaining.



AES has signed with the company union, and dully registered at the Ministry of Labor, a collective agreement, applicable to its employees and that could include all subcontractor companies employees hired to work on the construction of this project if both parts agree. Local labor regulations establish that when a company signs a collective agreement with a union, like in this case, all its affiliates, as well as non-affiliated employees of all subcontractors, are ruled by the on-going collective agreement, during the four years of its duration.



Non-discrimination and Equal Opportunity

The AES Corporate HR policy also includes provisions relating to non-discrimination and equal opportunity, wages and be
nefits and occupational health and safety. AES is an equal opportunity employer that extends equal employment opportunity to all applicants and its selection decisions are merit based.



As the hiring age in Panama is 18 years old and in compliance with the Panamanian law and PS2, the project as well as contracted personnel will be older than 18 years. The working periods during the construction phase will be specified in the EPC Contractor’s HR policy to be submitted to IFC according to action #10 of the ESAP. The operation phase will have three 8 hours shifts.



AES will comply with the Panamanian requirements as well as PS 2 as it will not have any forced labor and will prohibit workplace discrimination on the basis of race, nationality, disability, social class, sex, religion or political ideas. In addition, it will follow up the Panamanian constitution call for complying with national minimum wage and paying overtime for all work in excess of eight hours per day or 48 hours per week.



Grievance Mechanism

AES has a worker’s functional grievance mechanism that defines communication channels and includes the option of submitting grievances by mail, phone and in person. Workers who have concerns about illegal or unethical business conduct or questionable accounting, internal controls, or auditing issues, can contact their manager, an Ethics and Compliance Department representative, AES legal counsel, or another appropriate AES person. In addition, the AES Helpline is available 24 hours a day, seven days a week to request information or to report concerns (http://www.aeshelpline.com). AES Helpline posters providing local telephone numbers are also displayed at all AES operations. Contacts to the AES Helpline may be made anonymously, and all efforts are made to protect the confidentiality of anyone contacting the AES Helpline. This grievance mechanism is communicated to all employees and is an integral part of the human resources policy. For purposes of the project, the company will maintain a database with information regarding grievances, results of which will be reported quarterly.



Occupational Health and Safety (OHS)

The company has an established health and safety (OHS) at work policy. For the project, it will develop the corresponding plans and procedures for both construction and operation phases.



The EPC contractor will be responsible for developing EHS plan for the construction phase describing the procedures that will be followed to ensure safe working practices at the construction site as part of the EPC ESMS and as indicated in ESAP action #8. Procedures will include H&S induction training for all site personnel thus ensuring its personnel have the necessary skills to identify hazards and carry out their work responsibilities safely. Other procedures will include the recording and recordkeeping of all incidents and near misses and follow-up to prevent re-occurrences and the establishment of its own workplace condition
s monitoring program with which it will routinely report to the company it E&S performance. In addition, the company will commission independent monitoring and supervision of contractors operations to ascertain compliance with the agreed policies and procedures. Potential emergency scenarios will also be identified by the company in conjunction with the EPC contractor and adequate emergency response arrangements will be developed for implementation. This will include provisions for a trained and equipped emergency response team to be ready to respond to emergency events.



The company will include measures (noise barrier/insulation, periodic maintenance plans) to limit noise disturbance outside the site boundary. The company will establish a noise monitoring program at the facility boundaries to ascertain the project’s compliance with Panamanian standards and IFC guidelines. Noise monitoring will also be routinely carried out during the facility construction program and measures will be taken to minimize noise disturbance where necessary.



For the operation phase, the company will develop the OHS programs as indicated in ESAP action # 16. Even though, the company has begun identifying general H&S impacts in the workplace for the operation phase, it is being required to conduct job safety analysis for this phase to confirm that the measures proposed will ensure compliance with workplace conditions as per IFC requirements also as indicated in the ESAP action # 18.



Health checks will be made on workers during construction and operational phase prior to starting work to establish fitness for work and regular worker health checks will continue through the construction and operational phase to monitor workers health. A health service facility will be provided during construction and operation phases.

Resource Efficiency
The LNG terminal and the generation block will be installed in the same site, allowing synergies between both facilities, particularly with regard to the exchange of heat/cold for cooling of ambient air and operating the regasification system. The proposed combined cycle power generating facility uses one of the most highly efficient technologies for the generation of electric power. The General Electric 6FA Combustion Turbine efficiency increases from 35% when operating in simple cycle mode to 54.7% when operating in combined cycle mode. In a combined cycle mode the waste heat from the combustion turbines is captured in a heat recovery steam generator which transforms the waste heat into steam energy to drive a steam generator. The steam generator provides a secondary source of electric generation. Through this process, the overall project will take advantage of the highest level of efficiency of resource utilization, i.e. natural gas, by optimizing the generation of electricity per unit of natural gas input.

Additional efficiencies to be realized by the project are the result of optimizing the heat balance between the power plant and the adjacent LNG terminal. The LNG, which will be transported and stored at minus 160 degrees centigrade, requires the input of heat energy to raise the temperature of the LNG during the vaporization process to natural gas.

The project will optimize the overall thermal and resource efficiency through a closed loop water/glycol mixture, which will circulate through the vaporizers to warm the LNG and form natural gas, thus cooling the water/glycol mixture. The water/glycol mixture will then be sent to the power plant where it will be used in the combustion turbine inlet air chillers, thus increasing the overall efficiency of the turbines. The water/glycol mixture then will be sent to the power plants cooling water condenser, where it will pick up additional heat before returning to the LNG vaporizers, thus completing the loop. This process will improve the overall heat balance of the project while minimizing the discharge of heated/cooled water to the environment.

Water
For the operational water needs for both the power plant and LNG terminal, the Project will use approximately 25,073m3/hr of water from Limon Bay, of which approximately 24,000m3/hr will be discharged back to the same water body. The project will consume approximately 1,073m3/hr for process water makeup, potable water and other miscellaneous uses. The heat transfer optimization between the power plant and LNG terminal, presented above, not only minimizes the use of fuel for vaporization of the LNG, but also minimizes the use of water by taking advantage of the waste heat from the power plant to reduce the overall combined water intake and discharge of the overall project.

Water for construction will be purchased from a local vendor and delivered to the project site by truck. Operational process and potable water will come from an on-site desalination system utilizing reverse osmosis. Wastes from the RO system will be discharged through the cooling water system, which will be designed to meet both the applicable Panamanian regulatory requirements and those of the IFC.

The Project will have a 200 m sea-water pipeline with an intake depth of 8 m and a discharge pipeline with a discharge depth of 14 m. Both will be located at the limits of the Panama Port concession (with a distance of 600 m between them.

Potential sources of water pollution during construction of the onsite (power plant, LNG facility, berth, etc.) and offsite facilities (dredging) include sedimentation and runoff from the project site into Limon Bay, fuels and chemical spills.

The EPC contractor is being required by the company to establish controls such as use of silt barriers, hay bales and other methods as prescribed by good international industry practices (GIIP), to control sedimentation and runoff. Fuel and chemical spills will be controlled by ensuring equipment is operated in good condition, minimizing on-site equipment repair and maintenance, and providing adequate fuel and chemical storage areas with appropriate secondary containment. These measures will be presented in the EPC contractor Environmental Management Plan (EMP) for the project which will be prepared for the project.

Dredging
The EPC contractor will conduct dredging in an approximately 62 ha area to a 14 m depth for the channel access, dock, and ship maneuvering area. The estimated volume of sediment to be removed is 3.5 million m3. The dredge disposal site, Manzanillo-3, which is being authorized by the Panamá Maritime Authority (AMP) is located in Limon Bay approximately 8.7 km from the Project site, east of the breakwater. This site is currently used as a docking area for ships waiting passage through the Panama Canal and was identified previously by the AMP as one of the dredge spoil disposal areas for the dredging of the Panamá Canal.

As part of the ESIA, six samples from the sediment to be dredged were obtained to determine the potential presence of petroleum hydrocarbons and heavy metals possibly explained by the presence of nearby pollution sources (i.e., passage and berthing of ships, and the urban discharges of the Limon Bay.) The results, which were compared with those recommended by the Canadian Environmental Quality Guidelines (CEQGS, 2003), demonstrated elevated concentrations of arsenic and copper, potentially the result of adjacent port facilities. As the sediment has elevated concentrations of arsenic and copper, the dredging will be conducted using means to reduce the extent of the sedimentation plume such as conducting suction dredging, and installing siltation screens around this operation. The EPC contractor will develop a detailed dredging plan which will be submitted to IFC by the company as indicated in ESAP action # 11 prior to beginning the dredging operations. As the dredging is conducted, additional sediment sampling will be conducted to better characterize the sediments to be removed.

GHG Emissions
Combined cycle power plants are the most efficient fossil fuel fired technologies available today with correspondingly lower air emissions including CO2. The Project will generate 4,327 GWh/yr of electrical energy with annual CO2 emissions of 2.2 million tCO2/yr. This represents 8.3% of the total CO2 emissions based on the most recent information in Panamá which is from year 2000. Greenhouse gas (GHG) contributions from the facility will be routinely calculated and recorded during operations.

Pollution Prevention
As part of the ESIA, the company conducted physic-chemical characterization of the soil and groundwater in the project area. The results reported no soil contamination on the surface level. However, high lead concentrations were found in the underground water, which requires the EPC contractor taken additional mitigation measures to avoid any contact of this water with the sea during the construction process

Air Emissions and Ambient Air Quality
As part of the ESIA, the Institute of Analysis of the University of Panama conducted surveys in the area near the project site. The results reflected the activities in the vicinity of the project site such as passage of boats, vehicles and public transport, unpaved roads, landfill, fuel storage tank truck operation, etc. The measured ambient parameters (PM10, PM2.5, NO2, and SO2) reported some exceedances to the local required concentrations. Expected air emissions from the site preparation and construction include mainly combustion gases from energy generation and vehicles and machinery, and dust. Key control measures to be implemented during these phases include dust suppression though covered transport of excavated earth; water road spraying during the dry season, especially during strong wind conditions; regulated vehicles speed; regular road maintenance; grading and compacting road surfaces to prevent uneven running surfaces to prevent both noise and dust impacts. In addition, mandatory preventive vehicles and equipment maintenance to reduce generation of combustions gases will be also implemented. The EPC contractor environmental management plan will detailed these measures as well as the implementation procedures.

The air impacts during operation will be primarily generated through the combustion of natural gas at the power plant with emissions primarily of NOx, CO and CO2. Small amounts of air emissions during operation can also be expected from vehicles, LNG tanker ships, trim heaters at the LNG terminal (if required), and emergency diesel generators which will be operated infrequently. The project is being designed to comply with the IFC emissions requirements for gas fired and light fuel oil fired combustion turbines. For the operation phase, the company will install PM, SOx, NOx, CO2, CO and O2 continuous emission monitors to take real time measurements of the project stack emissions.

As part of the ESIA, the company conducted dispersion modeling using the USEPA ISCST3 v3-air dispersion model. The results of the model showed that the power plant impacts on ambient air quality will be also below both the Panamanian and IFC standards. During construction and operation, ambient air quality conditions, at the sensitive receptors identified as part of the air dispersing modeling, will be periodically conducted to ascertain that the good conditions are maintained.

Noise
Construction activities will take place over a period of approximately two years, primarily during daytime hours. Both, the construction and operation phases will generate noise. During construction, the noise will be temporary and associated with vehicle and equipment operation as well as potentially pile driving, blasting, and other construction related activities. The EPC contractor will take measures to reduce the noise levels operating in accordance with the IFC and national law noise requirements, even though there are no nearby communities with may be affected by the construction noise.

The Cadna/A® Noise Prediction Model (Version 4.4.145) was used to estimate sound levels at the nearest sensitive receptors (i.e., an unoccupied structure in Arco Iris, a single family home in Arco Iris, and a multifamily home in Cristobal) due to project operations at calm wind, northern and western wind conditions, The model results indicate that project operations during the daytime hours would be compliant with WHO and WBG guidance thresholds. The model also indicated that only during an infrequent but "worst-case wind scenario when six CTGs and two STGs are operating would noise from the project exceed the nighttime limit of 45 dBA at the nearest of the three NSRs. Analysis of individual sources in the project operations noise model scenarios developed revealed that the exhaust stacks are the loudest"and by a margin of several dBA above the next-loudest acoustical contributors. Therefore, aiming to operate according to compliance at all times, the project will design and install exhaust stack muffler, whenever it begins operating when six CTGs and two STGs, to help yielding overall noise reduction at the nearest sensitive receptors. In addition, the company will conduct periodic monitoring and, as needed, implement additional noise reduction measures to ensure it will operate in accordance with IFC and national law noise requirements

Wastewater Treatment
The baseline surface water analyses conducted in the project area reported that the fecal coliforms levels and the biological oxygen demand concentration, exceed local as well as IFC requirements. This is possibly due to the presence untreated wastewater discharges being made.

The Bay waters assessment results, close to the dredging area, indicating that only the fecal coliforms exceed the local as well as IFC requirements. This is due to the presence of coastal sewage discharges. In the dredging disposal area, studies provided by the ACP (URS, 2008) indicated that the site presents total and suspended solids levels above the local as well as IFC requirements. In the case of dissolved oxygen, they indicated values higher than 4.0 mg/l, indicating that the site presents conditions suitable for aquatic life.

The domestic wastewater during the construction phase will be handled by portable toilets. During operation, the sanitary wastes will be treated in a compact activated sludge wastewater treatment plant designed for the project in accordance to local and IFC requirements. The sludge will be transported off site by a licensed contractor and the treated effluent from the treatment facility discharged through the water circulation discharge pipe to Limon Bay.

For the power plant and the LNG terminal process wastewaters, AES will built a wastewater treatment system able to treat discharges to the required local and IFC requirements The oily plant drains will be pass through an oil water separator prior to final treatment and disposal. Once treated, the project wastewater will be discharged to Limon Bay.

To ensure that the project will emit temperatures lower than 3 degrees centigrade with respect to the average temperature of the discharge area in the mixing zone, the project designed a plant cooling discharge system. The discharge system will consist of a 60 m pipe with multi-port diffusors (30 holes - 2 m spacing) to optimize dispersion of the heated effluent within the bay. As part of the ESIA, the company ran thermal plume modeling, by using the CORMIX model. The results showed that the thermal plume will be reduced to 3 degrees centigrade within 100 m from the discharge pipe, thus complying with both the Panamanian and IFC thermal limit of 3 degrees centigrade above ambient temperature within 100 m. In addition, the discharge system was optimized based on a model simulation of the dispersion of the thermal plume and corresponding minimization of the area of involvement around the discharge points.

Soils
As the project site will be raised by approximately 3.5 m in elevation, a significant amount of fill from an offsite location will be required. AES will provide details of the fill sources, permitting schemes, as well as impacts and mitigations, along with a specific plan for the safe transport of the fill material along with a traffic management plan as indicated in the AES.

An incinerator, which is being operating in an area of approximately 5 ha located in the Southwest quadrant of the project site, is being removed. The incinerator operator conducted an initial soil assessment of two samples to assess the soil conditions of the incineration project site. Even though the results indicated no soil contamination, this operator commissioned a Phase II site assessment which included the collection and analysis of 60 soil samples and 6 groundwater samples distributed around the location of the incinerator and adjacent areas. The soil samples which were taken at 10 cm, 1 meter, and 20m depth, were analyzed for metals, chlorinated hydrocarbons, polycyclic aromatic hydrocarbons, aromatic compounds, PCBs, cyanide, acrylonitrile, acrylamide, microbiological analysis (Carbon microbial, soil microbial respiration (IAM)), nitrite, nitrate and sulfate. In addition groundwater samples were also taken and analyzed for alkalinity, oils and grease, cyanide, chloride, biological oxygen demand (BOD), detergents, total hydrocarbons, dissolved oxygen, color, pH, temperature, suspended solids, dissolved solids, floating solids, polycyclic aromatic hydrocarbons, turbidity and metals.

The Phase II report indicated that there were some contaminated areas. The groundwater results indicated that all parameters are within their respective maximum permissible limits with the exception of selenium which exceeded the limit at one site and lead which exceed the allowable limit at five of the six sampling stations The Project will also execute additional measures on the incinerator area to ascertain that the area has been completely remediated (if needed) before received it formally The results of this assessment will be submitted to IFC as per ESAP action # 4. The company will coordinate with the land owner about appropriate disposal if needed of soil material (according to samples to be taken during construction stage).

Solid Waste Management
The ESIA for the project indicated that approximately 0.75 m3/day of solid waste will be generated during the constructional phase. While an estimate of operational phase hazardous waste generation was not presented in the ESIA, it is expected that a smaller volume of solid waste would be generated in this phase of the project.

The wastes to be generated during the construction phase (i.e., packing materials, used lubricating oil, batteries, empty drums of paint/solvent/additives, oily sludge, contaminated soils from spills, electrical and mechanical components, etc.) will be segregated and properly stored in a temporary on-site waste disposal area managed by the EPC contractor. It is anticipated they will be disposed by licensed waste treatment contractors).

All operational wastes such as waste chemicals and lubricants, office wastes, used rags, packing materials and others will be strictly controlled and the waste management plan to be developed, as part of the management plans and procedures for the operation phase, the company 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, AES 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, AES 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 a government approved site for delivering hazardous wastes through an approved contractor.

Hazardous Materials
Various hazardous materials such as paints, lubricants and other construction related materials will be used during construction of the project. For the operation phase, the 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. The storage areas will be well-ventilated buildings and placed away from flammable materials and sources of heat, fire or explosion (i.e., gas pipelines, flammable liquids, flammable solids and combustible materials). They will undergo regular inspections and maintenance of electrical equipment and fittings; smoking will be strictly forbidden; and clearly displaying material safety datasheets and safety instructions in the storage area will be available.

The 180,000 m3 LNG storage tank will be designed to meet all applicable GIIP and Panamanian and IFC requirements. The tanks will be equipped with safety devices and instrumentation for the detection and monitoring of flows, to ensure protection against over-filling, overflow, over-pressure or vacuum under various modes of operation. The LNG will be stored at - 160 ° C, almost at atmospheric pressure, in a total containment tank. The tank is formed by two tanks, one inside another. The inner tank is cryogenic steel (that supports very low temperatures) and has a thickness of several cm. This tank is surrounded by insulating material and the outer tank, which is made of pre-stressed concrete 1 meter thick. In the unlikely event the metal inner tank were to suffer a leak, the outer tank would contain the LNG and any vapors.

Community Health and Safety

The health and safety of the communities near its operations is also of paramount importance to the company. The proposed project will be designed and constructed by an internationally recognized contractor with experience implementing LNG and gas fired power plant projects. The project will be designed, constructed and operated using Good International Industry Practice (GIIP) and is expected to meet applicable national and international guidelines, standards and safety codes. The LNG terminal design and equipment will be in line with proven technologies (e.g., a vessel certified by a recognized third party for the service as an LNG, transfer arms appropriate for continuous service, powered emergency release couplings, comprehensive emergency shutdown system, etc. Major risks from the facility were assessed as part of the Quality Risk Assessment (QRA) conducted.



Traffic volumes to transport workers, equipment and materials to the construction site will be considerable. For this reason, in addition to the mitigation measures identified in the ESIA, the company will prepare a Traffic Safety Management Plan as indicated in ESAP action # 16. This plan will establish the traffic volumes required and its impact in relation to the existing situation, the possible transportation routes and the traffic management measures to be employed that will reduce impacts; these include infrastructure upgrades, optimum route selection and vehicle management as well as the staggering of working hours and optimum site access provisions. Project–related vehicles will be modern and they will be continuously monitored to ensure their quality to minimize noise and vehicle emissions.



Infrastructure and Equipment Design and Safety

The LNG and power plant facilities will have controlled access with the property boundaries being fenced with guards posted at the access points at all times of the day and night.



Components of the LNG and power plant facilities are located approximately 1.25 km from the nearest residential sensitive receptors in the community of Arco Iris. There is a good vegetation buffer between the community and the project. Other industrial and port facilities are located within 0.25 km of the project site. Both LNG and gas fired power plants have good safety records on an industry wide basis.



Community Exposure to Disease

The mobilization of a large amount of workers (likely 2000 at the peak) to be hired during the construction phase may increase the risk of transmission of communicable diseases including sexually transmitted diseases. To monitor potential health impact on the local communities, the company will establish a health baseline for the surrounding communities prior to the inception of the construction phase to establish current health conditions of the nearby communities as indicated in ESAP action # 13. The company will also require the contractor to develop a Communicable Disease Managem
ent Plan. As part of this effort the company will jointly with the EPC contractors implement a communicable diseases awareness campaign in coordination with relevant stakeholders such as the women’s union, youth union, health workers and representatives from affected communities. In addition, to prevent the risk if spreading diseases triggered by vectors, any open area to be built as part of the wastewater treatment plant will be designed and built (i.e., aeration) to prevent it becoming a vectors breeding ground.



Influx

Significant induced influx of job seekers is not expected based on the local availability of skilled and unskilled workers. The company will broadly communicate its plan to prioritize local hiring and will conduct an employment survey to determine the capacity of the local workforce.



Operational Safety

The company’s design 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; complete wastewater treatment system to protect the local water system.



According to the Republic of Panama seismic hazard map the site is located in a low seismic risk area, with one acceleration less than 3.4 m/s2 on a scale that goes up to 6.2 m/s2. Hydrological and geomorphological characteristics on the terrestrial area of the project confers certain susceptibility to flooding, due to the pending existing flat, close to the coastal zone and the low altitude of the sector. An analysis of flooding potential at the project site was conducted and as a result, areas of the project site will be elevated by approximately 3.5 meters. According to the result of an analysis of susceptibility to landslides at the level of districts (environmental Atlas, 2010), it is observed that in the District of Colón, where the project is located the susceptibility to landslides is high. However, low slopes existing in the project area, as well as intervention and compacting existing in the environment, considerably reduce the probability of occurrence of landslides in the area.



AES commissioned a HAZID analysis, conducted in February 2016 where critical scenarios were selected by the assessment team and AES. The recommendations of this assessment will be integrated into the design and operation of the project. In addition, it also commissioned a (QRA) to determine potential risks associated to the operation of the LNG terminal. The assessment, which was conducted in March 2016, selected scenarios (i.e., releases where the flammable cloud is not immediately ignited, it extends to engulf a large porti
on -or all- of the terminal, and then ignites; a pool of LNG burns as it evaporates; flash fires; etc.) to evaluate potential risks and identify additional prevention and mitigation efforts. Project areas assessed included the LNG carrier moored at the terminal, the breakwater and jetty, LNG transfer equipment (e.g., arms, valves, piping), regasification unit, natural gas pipeline to the power plant and, several sections at the power plant. In addition, to the normal operation, the assessment also took into account the interim case of about one year when the LNG storage facility will be permanently moored to the dock sending the LNG to the onshore storage tank.



The assessments concluded that the LNG release events examined will be contained within the site boundaries as stipulated in NFPA-59A, thus, no buffer zone between the project boundaries and the surrounding areas will be required. In addition, AES commitment to implement the recommendations provided in the HAZID report, and use of best practices on handling LNG; as well as: design and operation based on established LNG codes and standards will ensure a sound and safe operation of the project.



As part of the detailed design engineering, the company will conduct an additional QRA to ascertain that once built there will not be significant negative risks. As needed, the project will incorporate the necessary changes resulting from this assessment. The results of this quantitative risk assessment will be submitted to IFC as indicated in ESAP action #22.



Emergency Preparedness and Response

As indicated above, for the construction phase the EPC contractors will be required to develop and implement an Emergency Response Plan and have qualified personnel and equipment response to potential emergencies and for the operation phase, the company will develop an Emergency Response Plan for its onsite as well as offsite operations. Qualified personnel to respond to any emergency will be available at all times. The company will also become active participant of the already established Emergency Response Organization established by the project area and will keep the local authorities, port authorities as well as communities abreast about the plans, response to emergencies, and the emergency drills to be conducted periodically.



Community Health Assessment and Participatory Monitoring

The company will also establish a community-based Participatory Monitoring program in the directly affected communities. The results of the monitoring will be externally communicated.



Security Personnel

For the construction phase, the EPC contractor will hire unarmed private security contractors for the security of the project personnel and property. As indicated in the ESAP action # 12, the EPC contractor will develop a Security Management Plan and it will submit it to IFC. Prior to developing the plan which will include background checks, training of private security forces, rules of engagement as
well as monitoring and reporting plans, the contractor will first conduct a security risk assessment. The training to be conducted to the security personnel to be hired is aimed to ensure a conduct aligned with PS 4 requirements. For the operation phase, the company will, in turn, develop, establish and implement a security management plan, satisfactory to IFC, as indicated in ESAP action #23.

A flora and fauna baseline was conducted as part of the ESIA, in the project area for the terrestrial and marine areas. In addition, as part of the ESIA for the T-line, it also conducted a general assessment of the flora and fauna on the general route definition of the T line.



Terrestrial Impacts

The natural vegetation characteristic of the terrestrial zone, which corresponds to three layers rainforest, has being totally degraded due to the high degree of anthropogenic impacts (namely the canal and terminal activities). Of the total area of direct influence, approximately 24 ha; only 9 % still has some presence of degraded vegetation in which the most representative species are grasses and another approximately 7 % of the project site with scattered trees.



Additionally, to the Northwest side of the project area, in the border between the coast and the sea there is a continuous wetlands strip approximately 30 meters wide and about 546 m long that occupies an area of approximately 2.7 ha, or 16.5% of the total terrestrial vegetation and 1,5 % of the area required for the project (177.614 has). All this vegetation will be removed to build the project. The species identified include white mangrove (Laguncularia racemosa) and button mangrove (Conocarpus erectus) as well as some individuals of Rhizophora mangle (red mangrove) in direct contact with the sea. Flora and fauna impacts related to the route of the transmission line will be fully determined once the detailed route is defined.



Of the total of species identified in the various types of vegetation (59), 6 species are in categories of certain conservation concern. Four (4) of these are classified as Vulnerable by the Panamanian authorities: Calophyllum longifolium, Conocarpus erectus, Prioria copaifera and Brassavola nodosa. Meanwhile two (2) species are listed in the IUCN Red Book catalog Laguncularia racemosa listed as endangered and Rhizophora mangle as of low concern.



Of 19 terrestrial fauna species identified in the area of influence of the project, both in the field and previous studies, only one species is classified as Vulnerable in the Panamanian legislation, the Barbinaranja parakeet (Brotogeris jugularis); two species are listed in Appendix II of CITES: Milvago yellow (Caracara cabeciamarilla) and perico barbinaranja (Brotogeris jugularis). Meanwhile fifteen species are listed in CITES as of low concern.



Prior to the site preparation phase, the company will conduct a capture and relocation fauna program under the guidance of qualified experts hired by the company to lead this effort. The ESIA included the fauna capture and relocation plan which establishes the methods and procedures to be follow by qualified experts hired by the company for this purpose. The Local authority approved this plan and the local company to execute it at the end of February, 2016.



In addition, to compensate for the loss of vegetation on the site, the company will develop a biodivers
ity management plan, as indicated in the ESAP action #6, for the (a) terrestrial (vegetation compensation) and (b) mangrove (Offsets Strategy) loss. The biodiversity monitoring plan will identify the locations for compensations, long-term biodiversity offset implementation and management, the biodiversity qualified resources to coordinate all the biodiversity aspects, the monitoring plan to determine how will ‘gains’ at the offset site be measured and monitored over time, among other aspects. For purposes of the mitigations for the Red Mangrove, the company will work together with the Smithsonian Institution, based in Panama.



Three nearby potential sites for quarrying sand, aggregates and boulders have been identified. The EPC contractor will source those materials from environmentally approved quarries.



Marine Impacts

Within the proposed dredging area, there are photosynthetic species such as algae, seagrass, and marine pastures, with high density of Thalassia testudinum, with areas of algae on dead brain coral in the shallower areas, none of which are identified as fragile species.



The protected Cove Island (Isla Galeta), is located approximately 3.5 km from the dredged material disposal area. Cove Island has an area of 605 ha area and it is covered by mixed forests, mangroves and a coralline platform off the coast. It also has a dedicated area for the scientific study of the high ecological value mangroves due to their excellent state of preservation by the Smithsonian Institute. The sediments dispersion modeling conducted as part of the ESIA which included prevailing currents, distances and conditions of dilution, among others; indicated that any potential negative impact as a result of the disposal of the dredged material is highly unlikely.



In the area of marine influence, although there were no registered vulnerable, endemic or endangered species; some migratory species are included in the IUCN protection categories, such as the turtle channel or lute (Dermochelys coriacea) listed as vulnerable, and the bottlenose dolphin (Tursiops truncatus), which is listed as one of low protection. As per the CITES classification, the spotted dolphin of the Caribbean (Stenella front) is included in CITES Appendix II.

Stakeholder mapping / analysis
The ESIA defined the project areas of direct and indirect socio-economic influence as consisting of six communities (Puerto Cristobal, Ciudad Arco Iris, Margarita, Barrio Norte, Barrio Sur, and Puerto Escondido) from the surrounding District of Colon. Around 60,000 people live in these communities located within a five-kilometer radius of the project site.

Stakeholders mapping and analysis began in 2015 with the ESIA for the terminal and plant. The company has since met with and analyzed the interests and influence of hundreds of local men and women including business leaders and representatives of workers’ organizations, students, government authorities, media and civil society representatives, etc. Of those interviewed, most (87% of people) endorsed the company’s plan to import natural gas for the purpose of producing energy at the proposed terminal location, whilst 6% of those interviewed indicated being against the project, and 7% were indifferent or had no opinion. Around 93% believed that the project will generate benefits such as jobs and energy, while 4% and 3% respectively did not believe the project to be beneficial, or did not know. On the subject of adverse impacts, 24% expressed concern about possible water and air pollution and/or loss of flora and fauna, whilst 60% did not perceive any such risk of adverse impacts, and 16% did not feel qualified to answer the question.

Stakeholder Engagement Plan
The company is committed to a robust stakeholder engagement process. The company is developing a Stakeholder Engagement Plan (SEP) in accordance to IFC requirements, through four stages: i) Diagnosis to identify the needs of the community through a qualitative study, consultation with authorities, civic clubs and local organizations; ii) Development of a social responsibility strategy and action plan that responds to local needs; iii) Validation of the plan with communities through focus groups; and iv) Implementation, monitoring and adjustment. Copy of the SEP will be submitted to IFC as indicated in the ESAP action # 1. The Community Relations Coordinator will ensure proper implementation of the SEP as well as management and expansion of the community liaison team as needed throughout the construction, operation and decommission phases of the project. In addition, the company is committed to updating the SEP for each phase of the project to identify, if present, additional stakeholders on local, national and international level. A community participatory monitoring program to be developed will be fully integrated into the SEP and serve to disseminate information on the company’s environmental monitoring program as well as to solicit feedback on community concerns.

Information Disclosure and Consultation
The ESIA methodology for disclosure and consultation involved delivery of brochures at key sites in the area, briefings with institutional actors, interviews with key stakeholders, surveys among a representative sample of the population, and consultation on the results of the ESIA.
As part of the Panamanian requirements for the issuance of the environmental license, the environmental authorities required the company to conduct a public consultation about the ESIA which took place on November 16th 2015 with the attendance of 147 people. According to ESIA regulations for category III projects in Panama, on 7 November 2015 the company published a notice in the local Crítica newspaper inviting the public to participate in the ESIA review process. The invitation described the project, provided a synthesis of E&S impacts and mitigation measures, and identified the time and place designated for viewing the ESIA and registering comments. The notice also specified that roundtrip transportation would be available for those interested in attending the 16 November consultation.

The public consultation included a high level of detail on each of the potential impacts addressed in the ESIA. The public was given the opportunity to learn more about the project and proposed impact mitigation as well as to provide their opinion. Overall, the public support the project, as long as the effects of the use of the imported gas does not affect public health or ecosystems. Interested stakeholders recommended that the company adopt stringent health and safety measures and provide training and information about these measures for workers and the public. IFC’s team met with approximately 20 community members during the project appraisal. The findings of this meeting reflect the opinions recorded during the public consultation sessions: there is overall strong support for the project in anticipation of employment. Community members also however expressed concern over potential environmental impacts to air, water, and biodiversity. A second informative meeting was also performed on March 1st, 2016 with the presence of 135 members of the community. As previously, the community emphasized its interest on employment opportunities and concerns about proper environmental management.

External Communications and Grievance Mechanisms
The company has hired a Community Relations Coordinator and several assistants. They are tasked to design and implement the communications strategy, the Corporate Social Responsibility plan, and manage community requests for information and public grievances.

The company’s External Communications and Grievance Mechanism processes include the option of submitting grievances by mail, telephone or face to face. Stakeholders with questions or concerns about any aspect of the project, including contractor performance, can contact the Community Relations Coordinator. This person records all queries received in a form that is then channeled to the relevant actors for follow up. Interested stakeholders will receive updated information over the project cycle through replies from the grievance mechanism and through feedback to affected communities to be provided at least once a year on aspects of the project / mitigation which could affect them as per PS 1.

Oficina de Ingenieria Municipal
Provincia de Colon
Panama

Biblioteca del Ministerio de Ambiente, Sede Allbrok
Ciudad de Panamá
Provincia de Panamá

AES Panamá Web page
http://www.AESPanama.com

Broad Community Support is not applicable for this project

Title	Anticipated completion Date
1) AES to develop and implement a Stakeholder Engagement Plan in keeping with IFC PS 1 requirements. The Stakeholder Engagement Plan must include preparation of detailed action plans on an annual basis for public consultation and meaningful disclosure activities, including, but not limited to: - Stakeholder identification and analysis - Disclosure of E&S Management programs and monitoring results - Disclosure of progress with ESAP actions that affect communities - Disclosure of key project information and updates	04/30/2016
2) AES to provide the organizational structure to meet commitments outlined in project documents.	04/30/2016
3) AES to set up information offices with pre-established service hours in local communities	06/30/2016
AES to develop a grievance management system that will be communicated and accessible to communities. The grievance mechanism will include the procedures to disseminate the availability of the grievance mechanism by the communities	04/30/2016
(a) Provide details of source (s) of material, impacts and mitigations, permit needed, and copy of those permits (b) Safety transportation and traffic management plan related to site filling material	04/30/2016
Conduct soil monitoring assessment to verify no soil nor ground water contamination after AES receives the project site	08/30/2016
1) AES to develop the consultant Terms of Reference (ToR) to develop the Biodiversity Management Plan	04/30/2016
2) AES to develop the Biodiversity Management Plan	05/31/2016
3) AES to provide approval of the Plan by the relevant environmental Panamanian authorities.	12/30/2016
a) Develop the management system structure and procedures to oversee the construction phase b) Provide the environmental, social, and health and safety key performance indicators KPIs that will be established to monitor EPC contractors performance	04/30/2016
(a) Provide a Copy of the EPC Contractor HSE organization structure (b) Provide copies of EPC Contractors’ HSE Management Plans for the construction phase, consistent with the principles of ISO 14001 for environment and OHSA 18001 for HS including KPIs, or equivalent Plans will include procedures, organizational resources (including roles and responsibilities), monitoring (including key performance indicators) and reporting requirements	04/30/2016
Develop the EHS and Social Monitoring Management Plan for the construction phase including marine and terrestrial activities	04/30/2016
EPC Contractors to develop and implement Human Resources policy and employment contracts in line with Panamanian labor law and IFC PS2	04/30/2016
Provide a copy of the EPC Contractor Dredging Management Plan including Sediments Management	04/30/2016
AES to develop a Security Management Plan for the project to include: - Background check of security personnel - Training of private and public security forces - Rules of engagement - Monitoring and reporting - Roles and responsibilities - Grievance mechanism	04/30/2016
AES to develop a Community Health Baseline Assessment covering Health Status Information of affected communities, available health facilities and services in the area; assessment of Project activities that may affect (positively or negatively) community health; and design and implementation of a mitigation and monitoring plan based on relevant key health indicators as recommended by the study	11/30/2016
Develop the EHS and Social Monitoring Management Plan for the operation phase for marine and terrestrial activities including parameters, frequencies, sampling locations, and Key Performance Indicators	09/30/2017
Develop and implement ESHS management plans and procedures for operations in accordance with the ESHS Management System covering key issues highlighted in the project ESIA and the ESRS	09/30/2017
Update the Stakeholder Engagement Plan, building on experiences during the implementation of the Plan for construction	09/30/2017
Conduct Job Risk Analysis identifying prevention and mitigation actions	06/30/2017
Develop and Implement a Greenhouse Gas (GHG) emissions reporting system that will routinely monitor GHG contributions from the project	09/30/2017
Develop and implement an Emergency Response and Spill Prevention Plan during the Operations Phase for the site as well as project transportation related activities, that will document accident/spill prevention measures (training, storage, handling) and spill response arrangements, and measures to be followed (including training, equipment to be used and reporting procedures) in the event of an accident/ spill	09/30/2017
Conduct HAZOP prior to the start of operations	06/30/2017
) Develop Process Safety Operation Procedures consistent with the process safety information. 2) Establish and implement MOC procedures to manage changes to process chemicals, technology, equipment, and procedures, and changes to the facilities that affect a process. 3) Develop and implement mechanical integrity procedures to maintain the ongoing integrity of process equipment particularly for the following equipment (a) pressure vessels and storage tanks; (b)piping systems (including piping components such as valves); (c) relief and vent systems and devices; (d) emergency shutdown systems; (e) controls (including monitoring devices and sensors, alarms, and interlocks); and (f) pumps	06/30/2017
(a) Once detail design is completed, update quantitative risk assessment during the detail design phase including modeling inputs, results, impacts and proposed mitigations (b) Once detail design is completed, confirm that operational safety measures designed for the FSU facility for the two scenarios (a) first year when vessel will be uploaded while stationary at the jetty, and (b) during the uploading for normal operation are appropriate	11/30/2016
Update Security Management Plan for operation phase	09/30/2017