Key E&S impacts potentially associated with this operation include air emissions, liquid effluent discharges, noise, handling of hazardous materials, land and marine biodiversity, water quality, GHG emissions, land acquisition, security, labor and community related impacts and risks during construction and operation. The proposed project is Category A per IFC’s Environmental and Social Sustainability Policy.

  The workforce required during project implementation is anticipated to reach approximately 2,359 direct and third-party contractors at peak construction. For the marine terminal, the peak workforce will be approximately 578 direct and indirect workers, while for the T-Line peak labor is 189, with a peak labor of 1,592 for the plant. Local communities have high expectations for employment opportunities, particularly among residents in Campos de Goytacazes.  

Working Conditions and Management of Worker Relationship

Human Resources Policies and Procedures

GNA is currently following Prumo’s human resources policy and code of conduct, which outlines its approach to complying with adequate working conditions, non-discrimination and equal opportunity, freedom of association and child and forced labor in line with PS2.   Per ESAP item # 9, GNA will develop and implement its own human resources policy and related procedures appropriate to its size and workforce, consistent with IFC PS2 and national law, and staff its human resources accordingly. These policies and procedures will provide clear reference to non-discrimination, equal opportunity, occupational health and safety, freedom of association and collective bargain, work-life balance, and prohibition of child and forced labor and be written in such a way as to be easily understood by workers. 

GNA will develop as per ESAP item # 10 a code of conduct that aligns with IFC PS2 and references its anti-discrimination policy, avoidance of child and forced labor, includes policy statements against sexual harassment, prioritizing local hiring. Information about the code of conduct will be provided during inductions to all direct and contract workers.  In addition, GNA will implement measures to manage the risk of gender-based violence as indicated in ESAP item # 11.  These measures will include: a) induction and training program on HR policies, procedures, code of conduct, and awareness about refraining from unacceptable conduct toward community members, specifically women; b) the grievance mechanism for handling any gender-based violence-related grievances; and c) cooperation of contractors in investigating complaints about gender-based violence.

Working Conditions and Terms of Employment

GNA’s total workforce is estimated at 2,359 the majority of which (1,592) will be working at the power plant, of these 300 workers will be considered migrant.  GNA will convert a hotel located 17 km from the project site to serve as accommodation for these workers.  The remainder of the workers will be hired locally with roughly 70% from Campos de Goytacazes and 30% from São João da Barra who will be bused to the work site daily by GNA or contractors.  Worker’s accommodation, will meet PS2 requirements. 

Worker’s Organizations

Brazilian labor law protects collective bargaining and the right to strike as well as defining minimum wage, overtime rates and working hours, worker’s compensation and entitlements. National law requires that a single union represent all Brazilian workers of an industrial sector in a given geographical area and requires workers to join the corresponding union. GNA will disclose information about the union agreement and representation during worker inductions including worker’s right to use GNA’s grievance mechanism.  

Non-Discrimination and Equal Opportunity

GNA has developed a recruitment plan that broadly aligns with IFC PS2 and includes anti-discrimination, forced labor, and child labor clauses. For construction and operation, GNA will make use of the “Employment Network”, a Porto do Açu initiative that promotes local employment. The network is currently undertaking a study to map skilled and non-skilled workers locally. The network will receive applications in electronic format and will prioritize local candidates as well as those with experience working at the Porto do Açu.  Both GNA and contractors will submit monthly reports of available positions to the recruitment network and Prumo’s and GNA’s stakeholder engagement and communication teams will disseminate information about job openings. 

GNA will strengthen its local recruitment by developing a local hiring plan as per ESAP item # 5 to define and implement strategies to increase hiring from residents of São João da Barra, from local fishers and from directly affected communities. These strategies will include: a) communicating job opportunities to local residents; b) hiring a staff member to enhance local recruitment; c) assisting local residents with the application process including facilitating access to computers and internet; d) defining policies prioritizing workers in the directly affected area (fishers, local residents, displaced people); e) broadly communicating GNA’s local hiring policies to minimize influx from job seekers; and f) define measures for monitoring and evaluation plan and redressing gaps.  

Retrenchment

GNA has developed policy statements related to demobilization of the workforce following completion of construction.  GNA will elaborate on these policy statements to develop a demobilization plan as part of the CMAP to ensure adequate communication to workers and government entities of the process of retrenchment and to prepare for demobilization. 

Worker’s Grievance Mechanism

GNA is currently using Prumo’s grievance mechanism. GNA will develop an internal labor grievance mechanism that is aligned with PS2 as per ESAP item # 12. 

Workers will have an option of using the grievance mechanism provided by the union or GNA’s. Additionally, GNA will broadly communicate to workers that they can access GNA’s worker’s grievance mechanism once it is developed. GNA will report results from the grievance mechanism to workers quarterly on public bulletin boards and other venues and will be able to receive and report on anonymous grievances. The grievance mechanism will be able to receive grievances via suggestions boxes, telephone and submitted directly to supervisors. The worker’s grievance mechanism will be administered internally by GNA’s human resource’s personnel.  

Occupational Health and Safety

The plans and procedures being developed as part of the IMS will include health and safety (H&S) induction training for all site personnel thus ensuring that its personnel have the necessary skills to identify hazards and carry out their work safely. Other procedures will include the recording and recordkeeping of all incidents, near misses, and follow-up to prevent re-occurrences. GNA will establish their own workplace monitoring program through which GNA will routinely internally report ESHS performance.  

  The main resources used by the project are natural gas and water. The LNG terminal and the generation block will be installed in the same site, allowing synergies between both facilities, particularly with regards to the exchange of heat/cold for cooling of ambient air and operating the regasification system.  The power plant will adopt state of the art technology for the gas turbines. The plant will utilize three high efficiency turbines from Siemens and one steam turbine model in a combined cycle mode, with efficiencies expected to reach 61%.

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.  

Seawater will be used to meet the power plant’s most significant water demand for cooling the condensate in the steam cycle. The cooling system will use forced draft cooling towers that require less water than a once-through cooling water system to help reduce this source of water use.  Moreover, to benefit from the cold water resulting from the LNG regasification process in the FSRU, this stream will be incorporated into the plant cooling water system to make a more efficient use of seawater and energy. 

Water Use & Wastewater Treatment

During construction, water is going to be extracted from a permitted well located on site. It is estimated that the daily water consumption will be 220 m3/day and used for construction activities as well as for human consumption.  A temporary water distribution system will be installed on the premises.  During operations, GNA will extract 33 m3/hour of groundwater from five permitted wells located in the Porto do Açu to produce water for the firefighting system, demineralized water for the equipment and potable water for human consumption. As part of the ESMPs of the IMS, GNA will develop a groundwater monitoring program to ensure that water extraction performed by GNA does not cause groundwater depletion, reducing the availability of the resource for neighboring communities, or deteriorating the water quality through seawater intrusion.

Liquid effluents generated during construction will be collected and transported for offsite treatment in wastewater treatment facilities that provide primary and secondary treatment.  The companies in charge of the collection, transport and treatment will be companies authorized by Brazilian authorities.  

In the operation phase, the project will extract 6,500 m3/hour of seawater from the south side of the marine terminal’s pier and will discharge back 5,590 m3/hour of cooling water to the same water body on the north side of the pier.  The submerged discharge pipe is 500m long and 24-inch in diameter. The point of discharge is 7.9m deep.  Environmental discharge modeling performed by GNA shows that a difference of 3°C between the discharge and surrounding water is achieved very close to the discharge point, at 0.5m horizontally and at a depth of 7m.

Three additional wastewater streams will be produced at the plant, treated prior to discharge, combined with the cooling water and discharged through the marine outfall.  These are: a) domestic sewage that will be treated in an on-site wastewater treatment plant; b) effluent from the demineralization system; and c) runoff water from industrial areas and drainage from the boilers’ water sampling system. These will be treated in a primary system comprised of grit removal, sedimentation and a compact oil & water separation unit process. These treated wastewater streams will be subsequently routed into a homogenization tank, where pH equalization will take place as needed prior to discharge through the marine outfall. Online measurement of pH, temperature, turbidity and conductivity will be provided. It is estimated that the three treated wastewater streams will add 23 m3/hour to the outfall.

GHG Emissions

With a 30% utilization per year, the estimated GHG for Scope 1 emissions of the plant will be 1.3 million tCO2/year. 

The approved preliminary license requires the Sponsors to develop an energy efficiency project equivalent to 1% of GNA’s installed capacity.  To comply with this requirement, GNA is proposing the development of three energy efficiency initiatives: a) A 10MW solar power project located west of the port’s substation and designed to supply energy to the local utility (ENEL Rio); b) an energy self-sufficiency project for the port’s visitor center; and c) a project to replace 3 MW of diesel generators with high efficiency batteries in different locations of the Port.

As mentioned in ESAP item # 13, GNA will provide a more detailed GHG inventory covering the Scope 1 and 2 as prescribed in the GHG protocol from World Resources Institute and the World Business Council for Sustainable Development for all project components, track them accordingly and report them on an annual basis.  

GNA will also develop a boil-off gas management plan following industry best practice to adequately manage and minimize any potential release of methane to the atmosphere from the FSRU, the LNG vessel and any other project component.

Pollution Prevention

Several pollution prevention measures are planned for the construction and operation phases of the project.  These include:  liquid effluents management and treatment prior to discharge, irrigation of roads and use of covered trucks to prevent dust generation, hazardous substances management, solid waste management applying the waste management hierarchy, surface runoff and drainage management, environmental control of work fronts and activities.

As indicated in ESAP item # 6, GNA will develop a comprehensive ESHS CMAP describing the controls to ensure that all the ESHS risks and impacts, including pollution prevention, are being properly managed during construction.  The development of an IMS aligned with ISO, OHSAS standards, and IFC PS (ESAP items # 1 and 2) will provide GNA with the necessary framework to conduct operations in an environmentally and socially sound manner.

Air Emissions and Ambient Air Quality

Baseline air quality monitoring completed in 2009 as part of the ESIA for the power plant indicates the air-shed is non-degraded for particulate matter (particles 10 and 2.5 micrometers in diameter, PM10 & PM2.5), Nitrogen dioxide (NO ₂ ), Sulfur dioxide (SO ₂ ), Carbon monoxide (CO), and ground level Ozone (O ₃ ). Measured concentrations of these substances were all below the applicable Brazilian regulatory limits. However, given that no recent data has been gathered, Brazilian environmental authorities (INEA) have requested GNA to perform a supplemental air quality baseline and monitoring program in 2018 well before the startup of operations of the project.  The program includes: (i) a new automated air quality and meteorological station that has been purchased and is to be installed to measure all the above-mentioned parameters as well as selected meteorological variables; (ii) an existing automated monitoring station that is already operating and measuring PM10, total particulate matter, and recording selected meteorological parameters; and (iii) six semiautomatic stations that are in operation and that will continue to monitor PM10 and total particulate matter..  The two automatic stations will be connected to the INEA online systems and data will be made available to the public though INEA’s air quality monitoring program web portal.  As per ESAP item # 14, GNA will ensure that the supplemental baseline and air quality monitoring is aligned with requirements set forth in the Air Emissions and Ambient Air Quality sections of IFC’s EHS General Guidelines, with due consideration to predominant meteorological conditions, results from air dispersion modelling, CIA studies, and location of receptors and stakeholders.

Expected air emissions from the site preparation and construction activities include mainly combustion gases from energy generation and construction related vehicles, machinery, and particulate matter (dust).  Key control measures to be implemented during site preparation and construction include dust suppression through covered transport of excavated earth, watering of dirt roads and areas of open soil for control of particulate matter, regulated vehicles speed, and regular road maintenance. In addition, mandatory preventive vehicles and equipment maintenance to reduce generation of combustions gases will be implemented. The EPC contractor’s environmental management plan will detail 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 plant with emissions primarily of NOx, CO and CO ₂ . Small amounts of air emissions during operation can also be expected from vehicles, LNG vessels, the FSRU, and emergency diesel generators, which will be operated infrequently. GNA will install a PM, SOx, NOx, CO ₂ , CO and O ₂  Continuous Emission Monitoring System (CEMS) on each of the power generation units to take real time measurements of stack emissions. Relative Accuracy Test Audits (RATA) will be performed every six months to ensure that the CEMS are functioning properly.

The Siemens gas turbines include dry low-NOx–DLN combustors designed to achieve = 25 ppm NOx at 15% O ₂  when fired on natural gas without the need for water injection for NOx control.  CO emissions are low for loads above 50% because of the turbine’s high efficiency combustion process and SOx emissions are usually very low in natural gas fired power plants because of the low concentrations of sulfur in the fuel. According to the technical specifications and documents provided by the sponsors, the emissions of the plant will meet the emission standards set forth in IFC EHS Guidelines for Thermal Power Plants and by Brazilian regulations.  

As part of supplemental studies, an assessment of potential impacts of project operational phase emissions to ambient air quality has been prepared with the use of predictive air dispersion models.  This supplemental assessment includes an evaluation of cumulative impacts to ambient air considering the operation of the plant and other future planned developments for the Port, and the industrial complex including the projected development of three additional gas-fired combined cycle power plants. The results of this cumulative impact analysis show that the combined impacts to ambient air from the plant and other current and reasonably foreseeable developments at the Porto do Açu will meet the applicable Brazilian ambient air quality standards. Nitrogen dioxide, the primary air pollutant from the plant will be well below both the 1-hr and annual average NO ₂  standards of 320ug/m ³  and 100ug/m ³  respectively. Regarding the IFC guideline that air emissions from a single project should not contribute more than 25% of the applicable ambient air quality standard, modeling results demonstrate that the plant will not exceed the 25% limit for the 98 ^th  percentile of the 1-hr NO ₂  standard as well as the annual average. 

The project design includes a CEMS to continuously monitor stack emissions from the plant. The presence of automated air quality and meteorological monitoring stations measuring air quality in real time will provide sufficient data and information to monitor compliance with applicable emissions and ambient air quality standards. 

Solid Waste & Hazardous Waste Management

GNA will include solid and hazardous waste management plans in the IMS that is being developed and will ensure that the EPC contractors duly comply with these procedures                                                   

   As described in previous sections of this ESRS, the project is located within the Porto do Açu, which is an industrial complex spanning over 90 km2 and comprising a large number of installations.   The project is largely considered Modified Habitat per PS6, although important biodiversity values are associated with the area.  

Porto do Açu is located with the Brazilian Atlantic Coast Restingas Ecoregion, which consists of three discrete areas of Restinga forests distributed from northeastern to southeastern Brazil.  Restinga forests are characterized by sandy coastal plains and dunes with shrubs and low forests found further inland. They support a diverse floristic community and are associated with endemism. They are highly threatened by urban expansion and are considered an Area of Permanent Protection (APP) by the Brazilian Forestry Code. Although the project is located in a highly industrialized area, remnant Restinga patches are present and therefore will be considered Critical Habitat per PS6.  

With respect to biodiversity values in the marine environment, a number of species are reported to be associated with the project’s area of influence. Given the wide distributions of these species globally, the project site is not considered Critical Habitat, but, as a precautionary approach, PS6 Natural Habitat requirements will apply to these biodiversity values. These include, inter alia, the Spiny Butterfly Ray ( Gymnura altavela  – IUCN Red List Vulnerable [VU]), the Tope Shark ( Galeorhinus galeus  -VU), Angular Angelshark ( Squatina Guggenheim  – IUCN Red List Endangered [EN]), Hidden Angelshark ( Squatina occulta  – IUCN Red List Critically Endangered [CR]), Largetooth Sawfish ( Pristis prisitis  - CR), Largetooth Sawfish ( Pristis pectinate  – CR), Brazilian Guitarfish ( Pseudobatos horkelii  – CR), Green sea turtle ( Chelonia mydas  – EN), the Loggerhead sea turtle ( Caretta caretta  – VU), the Leatherback sea turtle ( Dermochelys coriacea  – VU), the Hawksbill sea turtle ( Eretmochelys imbricate  – CR), and the Olive Ridley sea turtle ( Lepidochelys olivácea  – VU).  Although the shoreline is abutting an industrial zone, sea turtles are nesting along the beach.

Three separate ESIAs have been prepared for each of the project components. Data on biodiversity values were obtained through a combination of desktop reviews and field surveys for herpetofauna, birds, and mammals in terrestrial habitats, and for marine and freshwater phytoplankton, zooplankton, benthos, macrobenthos, sea turtles, and both freshwater and marine fish in marine habitats.  Data gathered included information obtained from other ESIAs for the different installations of the port, through ongoing biodiversity monitoring programs and from field inventories conducted for the project’s ESIAs developed in 2010, 2015 and 2017.  

Porto do Açu has developed a Cetaceans and Chelonia Monitoring Program (PMCQ), which also provided sea turtle data for the project’s ESIAs. The PMCQ includes several layers of monitoring including daily monitoring of the shoreline by trained supervisors, monitoring sea turtle movements in the larger area of influence and tracking occurrences of sea turtles in the region.  One element of the program involves a satellite telemetry monitoring project of Loggerhead sea turtles ( Caretta caretta ) that breed in the North Coast of Rio de Janeiro.  Data from the PMCQ is used to guide the implementation of avoidance and minimization measures of impacts on sea turtles from port activities (e.g., dredging, ship traffic, etc.).

The mitigation strategy as described in the ESIAs demonstrates adherence to the mitigation hierarchy. With respect to the Restinga habitat, 97% of impacts were avoided through design modification (5.6 hectares directly affected of the 180 ha in the area of influence).  The project sought the maximum amount of pre-existing cleared areas to develop so that the footprint could be minimized as far as possible.  With respect to the transmission line, four alternative routes were assessed to prioritize the avoidance of Restinga habitat.  Siting of the construction of the transmission line towers was based on vegetation mapping and included fauna rescue under the supervision of a team of wildlife biologists and tree pruning rather than cutting.  The project is now assessing alternative routes for the stringing of the cables considering biodiversity values, and bird flight diverters will be installed. 

  As part of the environmental licensing process GNA has prepared a summary of the ESIAs and conducted the consultation process mandated by regulatory authorities for the three ESIAs including public notifications.  The stakeholders included government officials from São João da Barra, Campos dos Goytacazes, fishers, communities surrounding the project area including: Barra do Açu, Mato Escuro, Pipeiras, Cajueiro, Barcelos, Villa da Terra resettlement, association of rural producers São João da Barra as well as FIRJAN (Federation of the Industries of the State of Rio de Janeiro), port workers and small business owners. In addition to the public consultation forums, GNA with the support of Prumo’s communication’s team, visited schools, universities, distributed information by news bulletins, on Prumo’s website and through social media.

Consultations were carried out in a participatory manner and all findings (including list of attendees) are recorded in official meeting minutes. Community members emphasized their interest in employment opportunities, potential increase in economic activities as well as benefits to community, to small business owners, to municipalities and availability of vocational training programs, as well as compensation programs defined by the ESIA and required by the state.  They also expressed concerns associated with potential project related environmental impacts on air and on the marine environment, emergency response plans, capacity of São João da Barra to maximize benefits, potential impacts of fishers, and the possibility that the municipality of São João da Barra will not benefit from the project.  Stakeholder mapping / analysis

GNA has mapped general stakeholders in the larger port area but will strengthen this effort as part of their SEP. GNA will conduct annual stakeholder mapping exercises to identify stakeholders and to plan engagement activities with a focus on economically and physically displaced families, artisanal fishers (both offshore and lagoon), and communities in the Porto do Açu area and along the T-Line corridor, as well as job seekers.

Stakeholder Engagement Plan

GNA will develop a project-specific SEP that aligns with IFC PS1 as part of ESAP item # 5. The plan will include the following elements at a minimum: a) company’s description; engagement principles, objectives and criteria; b) local regulations and international requirements; c) description of key social and environmental risks and impacts; d) summary of previous engagement activities; e) identification, analysis and prioritization of stakeholders, focusing on those directly affected including fishers, displaced people, job seekers, residents along the transmission line and residents of São João da Barra and residents surrounding the greater port area; f) action plan to be updated annually describing specific activities that will be conducted by GNA to communicate IMS plans, engage stakeholders and solicit feedback; g) description of GNA’s grievance mechanism and description of how GNA will monitor contractors’ grievance mechanisms during construction; and h) timetable, resources, and responsibilities. 

The SEP should also cross-reference other relevant management plans implemented by the company to manage environmental and social risks and impacts. The community relations coordinator will ensure proper implementation of the SEP as well as management and expansion of the community liaison team as needed throughout the construction and operation phases of the project. In addition, the company is committed to updating the SEP for each phase of the project, as appropriate and the action plan annually.

External Communications and Grievance Mechanisms

GNA is currently using Prumo’s grievance mechanism “Fale Conosco” which is recognized by all the surrounding communities. GNA will develop and implement a project-specific community grievance mechanism (as per ESAP item # 5) that includes methods to: a) communicate the grievance mechanism to communities and other potentially affected people; b) receive and register external communications from the public; c) screen and assess the issues raised and determine how to address them; d) provide, track, and document responses; e) provide feedback to stakeholders on grievance mechanism results; and f) monitor and adjust the management program including defining key performance indicators (KPIs), as appropriate. 

The mechanism should seek to resolve concerns promptly, using an understandable and transparent consultative process that is culturally appropriate and readily accessible, and at no cost and without retribution to the party that originated the issue or concern. The mechanism should not impede access to judicial or administrative remedies. Grievances will be able to be submitted via phone, email, and directly with the social management team.

Ongoing Reporting to Affected Communities

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

Company Gás Natural Açu S.A. - GNA

Point of Contact Joao Teixera

Title Manager